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NC0020354_Permit (Issuance)_20110602
NPDES DOCUMENT SCANNING: COVER :SHEET NC0020354 Pittsboro 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 Technical Correction Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: June 2, 2011 This document its printed on reuse paper - ignore any content on the resrerse *side NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary t1UNOE2 2011 Mr. William G. Terry, Town Manager Town of Pittsboro P. O. Box 759 Pittsboro, NC 27312 Subject: Issuance of Permit Modification and Renewal NPDES Permit No. NC0020354 Town of Pittsboro WWTP Chatham County Facility Class III Dear Mr. Terry: Division of Water Quality (Division) personnel have reviewed and approved your application for a major modification and renewal of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. It is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between NorthCarolina and the U.S. Environmental Protection Agency dated October 15, 2007. A public hearing was held on March 29, 2011 to obtain public comments on the draft permit, which proposed renewing the Outfall 001 discharge of 0.75 to Robeson Creek, and adding a new discharge of 2.47 MGD to the Haw River via Ouffall 002. Approximately 50 people attended, and 21 attendees provided oral comments. The public hearing officer reviewed these comments and the written comments, and recommended the following changes to the draft permit, which were incorporated into this final permit: • The facility proposes to treat to reuse standards. Given this proposed treatment, and the concerns expressed by recreational users of the Haw River near the Highway 64 canoe access, the Outfall 002 limits for fecal coliform were changed to the reuse water quality standards of 14 per 100 mL as a monthly average and 25 per 100 mL as a weekly average. • Upstream and downstream monitoring of fecal coliform must be performed at Ouffall 002 (Haw River),' regardless of whether or not the Town maintains membership in the Upper Cape Fear River Basin monitoring coalition. It was also recommended that these sampling data results be posted on the Town's website as soon as possible. This would provide easy public access to the data for those who are considering recreational use of the river. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury Si Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919-807-64951 Customer Service:1-877-623-6748 Internet: http: / / h2o.state.nc.us / • An Equal Opportunity ',Affirmative Action Employer NorthCarolina !VaiiraI/ji 4 The only other change to your permit from the draft permit sent to you September 29, 2010 is that footnote number 9 from Table A. (2) was changed to reflect the correct chronic toxicity test dilution (5.1 %) for the Haw River outfall. Please note that Robeson Creek is listed as an impaired waterbody on th- i !.. orth Carolina 303(d) Impaired Waters List. Outfall 001 contains TP limits to address th- 'oberson reek TMDL. Likewise, TN and TP limits are included in combined outfall C01 to address - _ . - . n Lake TMDL. Addressing impaired waters is a high priority with the Division, and instream data will continue to be evaluated. If there is noncompliance with the permitted effluent limits and stream impairment can be attributed to your facility, then mitigative measures may be required. If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable, you have the right to an adjudicatory hearing upon written request within thirty (30) days after receiving this letter. Your request must take the form of a written petition conforming to Chapter 150B of the North Carolina General Statutes, and must be filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such demand is made, this permit remains final and binding. This permit is not transferable except after notifying the Division of Water Quality. The Division may modify and re -issue, or revoke this permit. Please note that this permit does not affect your legal obligation to obtain other permits required by the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or other federal or local governments. If you have questions, or if we can be of further assistance, please contact Mr. Gil Vinzani at [gil.vinzani@ncdenr.gov] or call (919) 807-6395. Si o een H. ulli- s Enclosure: NPDES Permit FINAL NC0020354 Cc: US EPA Region IV, Pamala Myers (including fact sheet)* Raleigh Regional Office, Surface Water Protection Section Environmental Services Section, Aquatic Toxicology Unit, Susan Meadows* Hobbs, Upchurch & Associates (Adam Kiker, 300 SW Broad St., Southern Pines, NC 28388) Haw River Assembly (Elaine Chiosso, P.O. Box 187; Bynum, NC 27228) Construction Grants and Loans Section, Dan Blaisdell* NPDES Unit Files Central Files *E-mail Copy NPDES Permit No. NC0020354 • • STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, the Town of Pittsboro is hereby authorized to discharge wastewater from a facility located at the Town of Pittsboro WWTP Off Small Street Extension Chatham County to receiving waters designated as Robeson Creek and the Haw River in the Cape Fear River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV hereof. The permit shall become effective July 1, 2011. This permit and the authorization to discharge shall expire at midnight on April 30, 2016. Signed this day • /t) • Con H. Sullins, Director Division of Water Quality By Authority of the Environmental Management Commission • Page 1 of 11 • NPDES Permit No. NC0020354 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby superseded. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. The Town of Pittsboro is hereby authorized to: 1. Continue to operate an existing 0.75 MGD extended aeration treatment system consisting of the following components: • Manual and mechanical bar screen • Diffused aeration basins • Clarifiers • Phosphorous removal • High -rate sand filters • Sludge thickening • Aerobic sludge digestion • Ultraviolet disinfection • Effluent flow measurement • Cascade post aeration 2. After receiving an Authorization to Construct from the Division of Water Quality and submitting an engineer's certification, operate a 3.22 MGD extended aeration wastewater treatment system including the following components: • Grit removal system • Four anaerobic basins • Four oxidation ditches with anoxic zones • Four secondary clarifiers • Four tertiary denitrification filters • Sludge storage, thickening, and dewatering The facility is located at the Pittsboro WWTP off of the Small Street Extension, southeast of Pittsboro in Chatham County 3. Discharge from said treatment works at the location specified on the attached map into Robeson Creek (0.75 MGD, outfall 001), and into the Haw River (2.47 MGD, outfall 002), both classified as WS-W NSW waters in the Cape Fear River Basin. Page 2 of 11 ,i- Receiving Streams ; Outfall 001-Robeson Creek; Outfall 002-Haw River Outfall 001 Outfall 002 Latitude : 35 42'48"; 35 43'50 Longitude: 79°10'14", 79°06'23 • ~• Facility Location Quad #: E22NW, Pittsboro Sub -Basin: 03-06-04 Stream Class: WS-IV, NSW (both) 8-Digit HUC: 03030002 North Town of Pittsboro Chatham County NPDES Permit No. NC0020354 A.(1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — Outfall 001 Beginning upon the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge treated wastewater from Outfall 001 to Robeson Creek. Such discharges shall be limited and monitored by the Permittee as -specified below: EFFLUENT ` CHARACTERISTICS , ` '' -EFFLUENT LIMITATIONS '. MONITORING REQUIREMENTS < ...� f Monthly `1' Average. ;Weekly Average Daily Maximum Measurement ` Frequency , j Sample Type , 7 Y, , ,7 • :. Sample Locatlon� r , t ��; ,0. Flow 0.75 MGD Continuous Recording Influent or Effluent Total Monthly Flow (MG) Monitor & Report Monthly Recording or ' Calculated Influent or Effluent BOD, 5-day, (20°C) 2 (April 1— October 31) 5.0 mg/L 7.5 mg/L 3/Week Composite Influent & Effluent BOD, 5-day, (20°C) 2 (November 1— March 31) 10.0 mg/L 15.0 mg/L 3/Week , Composite Influent & Effluent Total Suspended Solids2 30.0 mg/L 45.0 mg/L 3/Week Composite Influent & Effluent NH3 as N 2.0 mg/L 6.0 mg/L 3/Week Composite Effluent Total Residual Chtorine4 17 pg/L 3/Week Grab Effluent pH 5 3/Week Grab Effluent Temperature (°C) Daily Grab Effluent Temperature (°C) _ 3/Week Grab Upstream & Downstream Dissolved 0xygen3 3/Week Grab Upstream &luentDownstream Fecal Coliform (geometric mean) 200/100 mL 400/100 mL 3/Week Grab Effluent, Upstream & Downstream Conductivity 3/Week Grab Effluent, Upstream & Downstream TKN Monitor & Report (mg/L) Weekly Composite Effluent NO3-N + NO2-N Monitor & Report (mg/L) Weekly Composite _ Effluent Total Nitrogen, -1146 Monitor & Report (mg/L) Weekly Composite Effluent TN Load VI Report (Ib/mo) Monitor & Report (lb/yr) Monthly Annually Calculated Effluent Total Phosphorus, TP Monitor & Report (mg/L) Weekly Composite Effluent Total Phosphorus, TP 9 2.0 mg/L Quarterly Average Weekly Composite Effluent TP Load's Monitor & Report (ib/mo) 322 lb (Apr. 1-Oct. 31) Monthly Seasonally Calculated Effluent Total Nickel 25 pg/L 261 pg/L Weekly Composite Effluent Total Copper Monthly Composite Effluent Total Zinc Monthly Composite Effluent Chronic Toxicity 10 Quarterly Composite Effluent All footnotes are listed on the following page. • • Page 3 of 11 NPDES Permit No. NC0020354 • Footnotes from Effluent Limitations and Monitoring Requirements (Outfall 001): 1. Sample locations: Upstream = at least 100 yards above the outfall; Downstream = at least 100 yards downstream from the outfall. Instream monitoring shall be conducted 3/Week during June, July, August, and September, and once per week during the remainder of the year. Instream monitoring is provisionally waived in light of the Permittee's participation in the Upper Cape Fear River Basin Association. Instream monitoring shall be conducted as stated in this permit should the Permittee end its participation in the Association. 2. The monthly average BOD5 and Total Suspended Residue concentrations shall not exceed 15% of the respective influent value (85% removal). 3. The daily dissolved oxygen effluent concentration shall not be less than 6.0 mg/1. 4. Total Residual Chlorine limit applies if chlorine or chlorine derivative is used for disinfection. The Division shall consider all effluent TRC values reported below 50 µg/1 to be in compliance with this permit. The Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory even if these values fall below 50 Ag/1. 5. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 6. TN = TKN + NOs-N + NO2 N, where TN is Total Nitrogen, TKN is Total Kjeldahl Nitrogen, and NOs-N and NOrN are Nitrate and Nitrite Nitrogen, respectively. 7. TN or TP Load is the mass quantity of Total Nitrogen or Phosphorus discharged in a given period of time. See Condition A. (6.). 8. Compliance with mass limits shall be determined in accordance with Conditions A.(4.) and A.(5.). 9. The quarterly average for total phosphorus shall be the average of composite samples collected weekly during each calendar quarter (January -March, April -June, July -September, October -December). 10. Chronic Toxicity (Ceriodaphnia) P/F at 90%; March, June, September & December. See Condition A.(7.). There shall be no discharge of floating solids or foam. • • Page 4 of 11 NPDES Permit No. NC0020354 • A.(2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - OutfAll 002 Beginning upon the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge treated wastewater from Outfall 002 to the Haw River. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS EFFLUENT LIMITATIONS MONITORING REQUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location' Flow (MGD) 2.47 MGD I Continuous Recording Influent or Effluent Total Monthly Flow ( MG) Monitor & Report MonthlyRecording or Calculated Influent or Effluent BOD, 5-day, (20°C) 2 (April 1 — October 31) 5.0 mg/L 7.5 mg/L Daily Composite Influent & Effluent BOD, 5-day, (20°C) 2 (November 1— March 31) 10.0 mg/L 15.0 mg/L Daily Composite Influent & Effluent Total Suspended Solids2 30.0 mg/L 45.0 mg/L Daily Composite Influent & Effluent NH3 as N (April 1— October 31) 1.0 mg/L 3.0 mg/L 3/Week Composite Effluent NH3 as N (November 1— March 31) 2.0 mg/L 6.0 mg/L 3/Week. Composite Effluent Total Residual Chlorine4 28 pg/L 3/Week Grab Effluent pH s Daily • Grab Effluent Temperature (°C) Daily Grab Effluent Temperature (°C) 3/Week Grab Upstream & Downstream Dissolved Oxygen3 3/Week Grab Effluent, Upstream & Downstream Fecal Coliform (geometric mean) 14/100 mL 25/100 mL Daily Grab Effluent, Upstream & Downstream Conductivity 3/Week Grab Effluent, Upstream & Downstream TKN Monitor & Report (mg/L) Weekly Composite Effluent NO3-N + NO2-N Monitor & Report (mg/L) Weekly Composite Effluent Total Nitrogen, TN6 Monitor & Report (mg/L) Weekly Composite. Effluent TN Load'�8 Monitor & Report (Ib/mo) Monitor & Report (lb/yr) Monthly Annually Calculated Effluent Total Phosphorus, TP Monitor & Report (mg/L) Weekly Composite Effluent TP Load'�8 Monitor & Report (Ib/mo) Monitor & Report (lb/yr) Monthly Annually Calculated Effluent Total Nickel Monthly Composite Effluent Total Copper Monthly Composite Effluent Total Zinc Monthly Composite Effluent Chronic Toxicity 9 Quarterly Composite Effluent All footnotes are listed on the following page. • Page 5 of 11 NPDES Permit No. NC0020354 i Footnotes from Effluent Limitations and Monitoring Requirements (Outfall 002): 1. Sample locations: Upstream = at least 100 yards above the outfall; Downstream = at least 100 yards downstream from the outfall. Instream monitoring shall be conducted 3/Week during June, July, August, and September, and once per week during the remainder of the year. Instream monitoring is provisionally waived in light of the Permittee's participation in the Upper Cape Fear River Basin Association. Instream monitoring shall be conducted as stated in this permit should the Permittee end its participation in the Association. However, upstream and downstream monitoring for fecal coliform must be performed and reported regardless of association membership. 2. The monthly average BODS and Total Suspended Residue concentrations shall not exceed 15% of the respective influent value (85% removal). 3. The daily dissolved oxygen effluent concentration shall not be less than 6.0 mg/1. 4. Total Residual Chlorine limit applies if chlorine or chlorine derivative is used for disinfection. The Division shall consider all effluent TRC values reported below 50 µg/1 to be in compliance with this permit. The Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory even if these values fall below 50 µg/1. 5. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 6. TN = TKN + NO3-N + NOrN, where TN is Total Nitrogen, TKN is Total Kjeldahl Nitrogen, and NO3-N and NO2-N are Nitrate and Nitrite Nitrogen, respectively. 7. TN or TP Load is the mass quantity of Total Nitrogen or Phosphorus discharged in a given period of time. See Condition A. (6.). - 8. Compliance with mass limits shall be determined in accordance with Conditions A.(4.) and A.(5.). 9. Chronic Toxicity (Ceriodaphnia) P/F at 5.1%; March, June, September & December. See Condition A.(7.). There shall be no discharge of floating solids or foam. A.(3.) COMBINED LIMITATIONS — Outfall CO1 (Combined Outfalls 001 and 002) During the period beginning on the dates specified below and lasting until permit expiration, the Permittee is subject to the following combined limitations for discharges from Outfalls 001 and 002 in addition -to any limits specified in Conditions A.(1.) and A.(2.) of this permit: EFFLUENT CHARACTERISTICS EFFLUENT LIMITATIONS MONITORING REQUIREMENTS .:: Monthly Average ._ Weekly ^ Average ._ :. Daily `Maximumrequeincy Measurement :. :.. Sample Type �, Sample Location Flow 3.22 MGD See Conditions A.(1.) and A.(2.) Combined 001 & 002 TP Delivered Load 2 Monitor and Report 3,731 Ib/yr Annually Calculated Combined 001 & 002 TN Delivered Load 2 Monitor and Report 27,514 Ib/yr (effective 1/1/2016) Annually Calculated Combined 001 & 002 Effluent Pollutant Scan See Condition A.(8.) Annually Grab or Composite Effluent Footnotes: 1. Values at Combined Outfall CO1 are the sum of the corresponding values at Outfalls 001 and 002. 2. Compliance with the nutrient limits shall be determined in accordance with Conditions A.( 5.) and A.(6.) of this permit. Page 6 of 11 NPDES Permit No. NC0020354 • A.(4.) NUTRIENT ALLOCATIONS AND LIMITS (a.) The Pittsboro WWTP is assigned Total Phosphorus (TP) and Total Nitrogen (TN) allocations under the following authorities: (i.) Robeson Creek Total Phosphorus TMDL, approved 1 / 13/2004. (ii.) Jordan Lake TMDL, approved 9/20/2007 and incorporated into Jordan Lake Nutrient Management Strategy — Wastewater Discharge Requirements, T15A NCAC 02B .0270 (the "wastewater rule"). The purpose of this condition is to list the allocations assigned to the Permittee and any changes in the allocations resulting from transfers to or from the Permittee. For compliance purposes, these allocations do not supersede any TN or TP limit specified elsewhere in this permit or in the NPDES permit of a compliance association of which the Permittee is a Co-Permittee Member. (c.) The Robeson Creek TMDL limits the discharge of Total Phosphorus from the Pittsboro WWTP into Robeson Creek (Outfall 001) to 3221b TP per summer season (April 1— October 31). (d.) The Jordan Lake TMDL and wastewater rule limit Total Nitrogen and Total Phosphorus contributions from point and nonpoint sources into Jordan Lake and its tributaries. The following table lists the allocations assigned to, acquired by, or transferred to the Permittee in accordance with the Jordan Lake wastewater rule and the status of each as of permit issuance. For compliance purposes, this table does not supersede any TN or TP limit established elsewhere in this permit or in the NPDES permit of a compliance association of which the Permittee is a Co- Permittee Member. (b.) Total Nitrogen Allocation ALLOCATION TYPE. Base Assigned by Rule (T15A NCAC 02B .0270) 8/11/09 ALLOCATION AMOUNT: Delivered (Ib/yr) 27,514 Discharge (lb/yr) 36,202 Active TOTAL 27,514 36,202 Active Footnote: (1) Nitrogen Transport Factor = 76% at Robeson Creek (Outfall 001), 99% at Haw River (Outfall 002). Total Phosphorus Allocation ALLOCATION TYPE DATE ALLOCATION AMOUNT » Delivered (Ib/yr) Discharge (Iblyr)' STATUS Base Assigned by Rule (T15A NCAC 02B .0270) 8/11/09 3,731 4,551 Active TOTAL 3,731 4,551 Active Footnote: r (1) Phosphorus Transport Factor = 82% at Robeson Creek (Outfall 001), 99% at Haw River (Outfall 002). (e.) Any addition, deletion, or modification of the listed allocation(s) (other than to correct typographical errors) or any change in status of any of the listed allocations shall be considered a major modification of this permit and shall be subject to the public review process afforded such modifications under state and federal rules. • Page 7 of 11 NPDES Permit No. NC0020354 • A.(5.) ANNUAL NUTRIENT LIMITS - Jordan Lake (a.) Total Nitrogen (TN) and Total Phosphorus (TP) allocations and load limits established under the Jordan Lake Nutrient Management Strategy for NPDES wastewater dischargers are annual values and apply on a calendar year basis. (The provisions of this special condition are limited to these annual limits and do not apply to seasonal limits established in the Robeson Creek TMDL.) (b.) For any given calendar year, the Permittee shall be in compliance with the annual TN (or TP) Load limit in this Permit if: (i.) ' the Permittee's annual TN (or TP) Load is less than or equal to the effective limit, or (ii.) the Permittee is a Co-Permittee Member of a compliance association. (c.) The TN (or TP) Load limit in this Permit may be modified as the result of allowable changes in the Permittee's allocations. (i.) Allowable changes include those resulting from purchase of TN (or TP) allocation from an authorized mitigation banker, the Ecosystem Enhancement Program, or other source allowed under applicable regulations; purchase, sale, trade, or lease of allocation between the Permittee and other dischargers; regionalization; and other transactions approved by the Division. The Permittee may request a modification of the TN (or TP) Load limit in this Permit to reflect allowable changes in its allocation(s). (A) Upon receipt of timely and proper application, the Division will modify the permit as appropriate and in accordance with state and federal program requirements. (B) Changes in TN (or TP) limits become effective on January 1 of the year following permit modification. The Division must receive application no later than August 31 for changes proposed for the following calendar year. Any requests for modification should be sent to: NCDENR/ DWQ/ NPDES Programs Attn: Jordan Lake Watershed Coordinator 1617 Mail Service Center Raleigh, NC 27699-4617 (d.) If the Permittee is a member and co-permittee of an approved compliance association on January 1 of a given year, its TN and TP discharges during that year are governed by that association's group NPDES permit and the limits therein. (i.) The Permittee shall be considered a Co-Permittee Member for any given calendar year in which it is identified as such in Appendix A of the association's group NPDES permit. (ii.) Association roster(s) and members' TN and TP allocations will be updated annually and in accordance with state and federal program requirements. (iii.) If the Permittee intends to join or leave a compliance association, the Division must be notified of the proposed action in accordance with the procedures defined in the association's NPDES permit. (A) Upon receipt of timely and proper notification, the Division will modify the permit as appropriate and in accordance with state and federal program requirements. (B) Membership changes in a compliance association become effective on January 1 of the year following modification of the association's permit. (e.) The TN and TP monitoring and reporting requirements in this Permit remain in effect throughout the term of the Permit and are not affected by the Permittee's membership in a Page 8 of 11 NPDES Permit No. NC0020354 ' compliance association. A.(6.) CALCULATION AND REPORTING OF NUTRIENT LOADS The Permittee shall calculate and report monthly and annual nutrient loads as follows: (a.) Calculation of Discharge Loads (Outfalls 001 and 002): The Permittee shall calculate monthly and annual discharge loads for each outfall as follows: (i.) Monthly Discharge Load (lb / mo, TN or TP) = TN (or TP) x TMF x 8.34 where: TN (or TP) = the average Total Nitrogen (or Total Phosphorus) concentration (mg/L) of the composite samples collected during the month TMF = the Total Monthly Flow of wastewater discharged during the month (MG/mo) 8.34 = conversion factor, from (mg/L x MG) to pounds (ii.) Annual Discharge Load (lb/yr, TN or TP) = Sum of the 12 Monthly TN (or TP) Loads for the calendar year (b.) Calculation of Delivered Loads (Outfall C01): The Permittee shall calculate annual delivered loads as follows: (i.) Individual Outfalls 001 & 002: Annual Delivered Load (lb/yr, TN or TP) = Annual Discharge Load (lb/yr) x TF where TF = Transport Factor for each outfall, as specified in Condition A.(4.), Nutrient Allocations and Limits. (ii.) Combined Outfall C01: Annual Delivered Load (lb /yr, TN or TP) = Sum of the Outfall 001 & 002 Annual Delivered TN (or TP) Loads for the calendar year (c.) Reporting of Nutrient Discharges: The Permittee shall report monthly TN and TP discharge loads for Outfalls 001 and 002 in the appropriate discharge monitoring report. (d.) Reporting of Combined Delivered Loads: The Permittee shall report each calendar year's combined delivered loads for Outfall C01 with the December report for that year and shall append the report with a summary of monthly loads and calculations. • • Page 9 of 11 NPDES Permit No. NC0020354 A.(7.) CHRONIC TOXICITY PERMIT LIMITS (QUARTERLY) The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 90% at Outfall 001 (Robeson Creek) and 5.1% at Outfall 002 (Haw River). The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of March, June, September, and December. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure, performed as the first test of any single quarter, results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months, as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised - February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address: NCDENR/ DWQ/ Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be . complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document (such as minimum control organism survival, minimum control organism reproduction, and/or appropriate environmental controls) shall constitute an invalid test and will require immediate follow-up testing, to be completed no later than the last day of the month following the month of initial monitoring. Page 10 of 11 NPDES Permit No. NC0020354 • • A.(8.) EFFLUENT POLLUTANT SCAN The Permittee shall perform an annual Effluent Pollutant Scan for all parameters listed in the table below (in accordance with 40 CFR Part 136). The annual effluent pollutant scan samples shall represent seasonal (summer, winter, fall, spring) variations over the 5-year permit cycle. Unless otherwise indicated, metals shall be analyzed as "total recoverable."Additionally, the method detection level and the minimum level shall be the most sensitive as provided by the appropriate analytical procedure. Ammonia (as N) Trans-1,2-dichloroethylene Bis (2-chloroethyl) ether Chlorine (total residual, TRC) 1,1-dichloroethylene Bis (2-chloroisopropyl) ether Dissolved oxygen 1,2-dichloropropane Bis (2-ethylhexyl) phthalate Nitrate/Nitrite 1,3-dichloropropylene 4-bromophenyl phenyl ether Kjeldahl nitrogen Ethylbenzene Butyl benzyl phthalate Oil and grease Methyl bromide 2-chloronaphthalene Phosphorus Methyl chloride 4-chlorophenyl phenyl ether Total dissolved solids Methylene chloride Chrysene Hardness 1,1,2,2-tetrachloroethane Di-n-butyl phthalate Antimony Tetrachloroethylene Di-n-octyl phthalate Arsenic Toluene Dibenzo(a,h)anthracene Beryllium 1,1,1-trichloroethane 1,2-dichlorobenzene Cadmium 1,1,2-trichloroethane 1,3-dichlorobenzene Chromium Trichloroethylene 1,4-dichlorobenzene Copper Vinyl chloride 3,3-dichlorobenzidine Lead Acid -extractable compounds: Diethyl phthalate Mercury* P-chloro-m-cresol Dimethyl phthalate Nickel 2-chlorophenol 2,4-dinitrotoluene Selenium 2,4-dichlorophenol 2,6-dinitrotoluene Silver 2,4-dimethylphenol 1,2-diphenylhydrazine Thallium 4,6-dinitro-o-cresol Fluoranthene Zinc 2,4-dinitrophenol Fluorene Cyanide 2-nitrophenol Hexachlorobenzene Total phenolic compounds 4-nitrophenol Hexachlorobutadiene Volatile organic compounds: Pentachlorophenol Hexachlorocyclo-pentadiene Acrolein Phenol Hexachloroethane Acrylonitrile 2,4,6-trichlorophenol Indeno(1,2,3-cd)pyrene Benzene Base -neutral compounds: Isophorone Bromoform Acenaphthene Naphthalene Carbon tetrachloride Acenaphthylene Nitrobenzene Chlorobenzene Anthracene N-nitrosodi-n-propylamine Chlorodibromomethane Benzidine N-nitrosodimethylamine Chloroethane Benzo(a)anthracene N-nitrosodiphenylamine 2-chloroethylvinyl ether Benzo(a)pyrene Phenanthrene Chloroform 3,4 benzofluoranthene Pyrene Dichlorobromomethane Benzo(ghi)perylene 1,2,4-trichlorobenzene 1,1-dichloroethane . Benzo(k)fluoranthene 1,2-dichloroethane Bis (2-chloroethoxy) methane Test results shall be reported to the Division in DWQ Form- DMR PPA1 or in a form approved by the Director within 90 days of sampling. The report shall be submitted to the following address: NC DENR/ DWQ/ Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617. *Mercury samples shall be analyzed using EPA, Method 1631E. Page 11 of 11 NCDENR / DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT Town of Pittsboro Wastewater Treatment Plant NPDES No. NC0020354 :Miscellaneous Information`: (1) Facility: Pittsboro WWTP, off of Small Street Extension (2) Permitted Flow: 3.22 MGD (6) County: Chatham (3) Facility Class: IV (7) Regional Office: Raleigh (4) Facility Status: New (8) USGS Topo Quad: E22NW Pittsboro (5) Permit Status: Major Mod. and Renewal (9) Permit Writer: Gil Vinzani . StreamteChara-cteristics (1) Receiving Stream: (1): Robeson Creek — 0.75 MGD; (2): Haw River — 2.47 MGD (2) Subbasin: 03-06-04 (7) Summer 70310: (1) 0.03 cfs (2) 71.8 cfs (3) Drainage Area: (1) 10.5 sq. mi. (2) 1275 mil (8) Winter 7010): (1) 0.41 cfs (2) 125.6 cfs (4) Streams Classifications: WS-IV, NSW (both) (9) 30Q2: (1) 0.4 cfs (2)159 cfs (5) 303(d) Listed: (1) Yes; (2) No (10) Average Flow: (1) 10 cfs (2) 1240 cfs (6) 8-Digit HUC: 03030002 (11) IWC: (1) 100%; (2) 5.06% f- 3°Q Summary and Permit History • The Town of Pittsboro operates an extended aeration 0.75 MG astewater treatment plant that discharges into Robeson Creek; class WS-IV NSW wate in the Cape Fear River Basin. This creek is tributary to Jordan Lake, flowing into t, e lake forming one of its northwest arms. Flows are so low that it , a be tream for wastewater permitting purposes. Algalbloomshave been observed within this arm during recent years and this reach of the stream has been placed on the state's 303(d) list because sampling there has shown exceedances of the water quality standard for chlorophyll -a. The causative pollutant is phosphorous. Therefore, in 2004, the stream was given a Total Maximum Daily Load (TMDL) for total phosphorous (TP) that must be met during the summer months (April through October). Because the Town of Pittsboro WWTP is the only known point source discharger into the creek it is the sole point source contributor of phosphorous and is liable for the entire point source load reduction established to implement the TMDL. NPDES PERMIT FACT SHEET Town of Pittsboro WWTP NC0020354 • Since the WWTP as it exists today cannot meet the very stringent Jordan Lake TMDL for TN and TP, a new treatment facility was proposed. The expanded capacity also addresses the necessity of serving an increasing population. • Originally, this application was assigned a new NPDES permit number (NC0088943). After internal discussion, it was decided to retain the NC0020354 number, for administrative continuity. This expansion request will therefore be treated as both a major modification and a renewal. The existing permit expires April 30, 2011. • The new 3.22 MGD treatment plant will have two outfalls and be located adjacent to the existing plant. It will be a BNR plant with nutrient removal and tertiary filters. Outfall 001 will discharge 0.75 MGD to Robeson Creek at the present outfall site; Outfall 002 will discharge 2.47 MGD to the Haw River at the US 64 bridge. • The Town at present has an inactive pretreatment program. According to the Pretreatment Unit, there are currently no SIU's. In order to achieve the TP TMDL for Robeson Creek, outfall 001 must cap its summer (April to October) discharge at 0.68 kg/day, or 0.24 mg/L at the design flow of 0.75 MGD. • An engineering alternative analysis was included as part of the Environmental Impact Statement. A draft record of decision (ROD) was issued for this EIS on March 19, 2010. • The section of Robeson Creek downstream of the proposed WWTP is listed as impaired on the 2010 303(d) list for Biological Criteria. The Haw River site at Outfall 002 is not 303(d) listed, although it is located above a section of the river that is impaired for chlorophyll -a. • A new permit modification for NC0020354 was issued on July 9, 2010. This modification accounted for the Jordan Reservoir Nutrient Management Strategy rules. These rules established maximum Toad allocations for nitrogen and phosphorus, which will be continued for this permit. DMR Data. • Flow: According to the application, the average daily value flow at the existing WWTP is 373,000 gallons per day. A review of the facility's DMRs shows that current flows are actually higher than that, and are increasing. Nutrient data is available only starting from 2009. See table below for DMR flows and nutrient sampling results: Time Period Flow (MGD) TP (Ibs/month) TP (mg/L) TN (Ibs/month) TN (mg/L) 2007 0.361 2008 0.400 2009 — April 2010 0.424 78.6 1.1 2402 19.8 Compliance DMRs were evaluated for a period from January 2007 until the present. The many exceedances listed include the following which were issued notices of violation or became part of enforcement cases: Dissolved oxygen under the 6.0 mg/L limit 47 times; BOD-5 over the limit 18 times, the latest being very recently; fecal coliform twice, once in October of 2007 and once in September NPDES PERMIT FACT SHEET Town of Pittsboro WWTP NC0020354 2009; ammonia -nitrogen once and total suspended solids three times. In addition, monitoring frequency violations were enforced four times during this evaluation period. Overall, the existing facility has had a poor compliance record. This fact supports the decision to construct a new facility. Permitting Strategy As stated, effluent from the proposed facility will be split into two outfalls: the 2.47 MGD new outfall to the Haw River and the 0.75 MGD existing outfall into Robeson Creek. Separate limits pages were proposed for outfalls 001 and 002. A third outfall, outfall C01, was created in order to apply the nutrient limits that are in effect for the combination of both outfalls. Nutrient limits were given both individually for each outfall, and collectively. The TMDL caps the discharge at outfall 001 (Robeson Creek) at 322 pounds of TP for the summer season (April through October). In addition, an existing TMDL and the Jordan Lake Rules limit the combined TN input from the facility at 27,514 pounds per year, and TP at 3731 pounds per year. These figures represent pounds delivered to Jordan Lake, and must be calculated using a transport factor, which account for stream attenuation prior to discharge. TP and TN limits must be calculated to account for loading to the lake, rather than Toads measured at discharge points. Transport Factors are as follows: Outfall TN Transport Factor TP Transport Factor 001 (Robeson Creek) 76% - 99% 002 (Haw River) _ 82% . 99% The proposed nutrient limits (and several limits for conventional parameters) in both outfalls are the same as shown in the speculative limits letter issued to the Town on July 25, 2008. At the new outfall 002, parameters of concern, including nickel, copper, and zinc, will have a monthly monitoring requirement. This monitoring frequency was proposed in accordance with the Division's policy on monitoring frequencies for toxic substances. Nickel is included due to its presence in the previous permit, in which it was limited and monitored weekly. For outfall 001, the nickel limit will remain. Like nickel, zinc and copper (action level parameters) will be monitored until it is shown that there is no reasonable potential for the effluent to cause an exceedance of water quality standards in either receiving stream. Toxicity Data The existing facility passed all of its whole effluent toxicity tests from 2006 until the present. Reasonable Potential Analysis This permit modification request was to allow for an expansion of wastewater treatment facilities. No new RPA analysis was conducted, since the proposed facility is new and the permit covering the existing was modified very recently (July 9, 2010). Changes from the Previous Permit • Outfall 002 was added to allow for the expanded discharge into the Haw River. Grade IV facility monitoring frequencies were applied. • A combined artificial outfall C01 was added in order to apply nutrient limits and conditions applicable to the combination of outfalls 001 and 002. These conditions satisfy total phosphorus and total nitrogen requirements for both TMDLs (Jordan Lake and Robeson Creek). NPDES PERMIT FACT SHEET Town of Pittsboro WWTP N C0020354 • The TRC limit at outfall 001 was corrected to 17 pg/L. The standard footnote was added to state that the Division shall consider all effluent TRC values reported below 50 pg/lto be in compliance with this permit. The Permittee shall continue to record and submit all values reported by a North Carolina certified laboratory even if these values fall below 50 pg/I. Proposed Schedule for Permit Issuance Because this permit expires on April 30, 2011, it was decided to combine this request for permit modification with a renewal. A public hearing has been scheduled for March 29, 2011. Since the final permit will not be ready to issue until after the end of April, the expiration date of the new permit will be April 30, 2016. Draft Permit to Public Notice: September 29, 2010 Public Hearing March 29, 2011 The final permit will be issued within 90 days of the close of the record after the public hearing, at the discretion of the Director of Water Quality. State Contact If you have any questions on any of the above information or on the attached permit, please contact Mr. Gil Vinzani at (919) 807-6395, or at gil.vinzani@denr.gov SIGNATURE: DATE: Ma v 19. 2011 IWC Calculations Facility: Town of Pittsboro Outfall 002 NC0020354 Prepared By: GTV Enter Design Flow (MGD): Enter s7Q10 (cfs): Enter w7Q10 (cfs): 2.47 71.8 125.6 Total Residual Chlorine (TRC) Daily Maximum Limit (ug/I) s7Q10 (CFS) DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (UG/L) Upstream Bkgd (ug/I) IWC (%) Allowable Conc. (ug/I) Fecal Coliform Monthly Average Limit: (If DF >331; Monitor) (If DF<331; Limit) Dilution Factor (DF) 71.8 2.47 3.8285 17.0 0 5.06 336 Ammonia (Summer) Monthly Average Limit (mg NH3-N/I) s7Q10 (CFS) DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (MG/L) Upstream Bkgd (mg/I) IWC (%) Allowable Conc. (mg/I) Ammonia (Winter) Monthly Average Limit (mg NH3-N/I) w7Q10 (CFS) 200/100mI DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (MG/L) 19.75 Upstream Bkgd (mg/I) IWC (%) Allowable Conc. (mg/I) Total Residual Chlorine 1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity Ammonia (as NH3-N) 1. If Allowable Conc > 35 mg/I, Monitor Only 2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg/I 3. Monthly Avg limit x 5 = Daily Max limit (Non-Munis); capped at 35 mg/I 4. BAT for Minor Domestics: 2 mg/I (summer) and 4 mg/I (winter) 5. BAT for Major Municipals: 1 mg/I (year-round) 71.8 2.47 3.8285 1.0 0.22 5.06 15.6 125.6 2.47 3.8285 1.8 0.22 2.96 53.6 Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni) NPDES Server/Current VersionsNVLA; TB 1/16/2009 IWC Calculations Facility: Town of Pittsboro Outfall 001 NC0020354 Prepared By: GTV Enter Design Flow (MGD): Enter s7Q10 (cfs): Enter w7Q10 (cfs): 0.75 0.03 0.41 Total Residual Chlorine (TRC) Daily Maximum Limit (ug/I) s7Q10 (CFS) DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (UG/L) Upstream Bkgd (ug/I) IWC (%) Allowable Conc. (ug/l) Fecal Coliform Monthly Average Limit: (If DF >331; Monitor) (If DF<331; Limit) Dilution Factor (DF) 0.03 0.75 1.1625 17.0 0 97.48 17 Ammonia (Summer) Monthly Average Limit (mg NH3-N/I) s7Q10 (CFS) DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (MG/L) Upstream Bkgd (mg/I) IWC (%) Allowable Conc. (mg/I) Ammonia (Winter) Monthly Average Limit (mg NH3-N/I) w7Q10 (CFS) 200/100mI DESIGN FLOW (MGD) DESIGN FLOW (CFS) STREAM STD (MG/L) 1.03 Upstream Bkgd (mg/I) IWC (%) Allowable Conc. (mg/I) Total Residual Chlorine 1. Cap Daily Max limit at 28 ug/I to protect for acute toxicity Ammonia (as NH3-N) 1. If Allowable Conc > 35 mg/I, Monitor Only 2. Monthly Avg limit x 3 = Weekly Avg limit (Municipals); capped at 35 mg/I 3. Monthly Avg limit-x 5 = Daily Max limit (Non-Munis); capped at 35 mg/I 4. BAT for Minor Domestics: 2 mg/I (summer) and 4 mg/I (winter) 5. BAT for Major Municipals: 1 mg/I (year-round) 0.03 0.75 1.1625 1.0 0.22 97.48 1.0 0.41 0.75 1.1625 1.8 0.22 73.93 2.4 Fecal Coliform 1. Monthly Avg limit x 2 = 400/100 ml = Weekly Avg limit (Municipals) = Daily Max limit (Non -Muni) NPDES Server/Current VersionsfWLA; TB 1/16/2009 TOWN OF RANDOLPH VOLLER Mayor WILLIAM G. TERRY Town Manager PAUL S. MESSICK, JR. Town Attomey P.O. Box 759 — 635 East Street PITTSBORO, N.C. 27312 Mr. Tom Belnick, Supervisor NPDES Complex Permitting Unit 1617 Mail Service Center Raleigh NC 27699-1617 Subject: Town of Pittsboro WWTP Minor Permit Modification Request Dear Mr. Belnick, BOARD OF COMMISSIONERS GENE BROOKS HUGH HARRINGTON PAMELA BALDWIN MICHAEL A. FIOCCO CLINTON E. BRYAN III TELEPHONE (919) 542-4621 FAX (919) 542-7109 05/31/2011 /Y1A0 fru 64-ii(t‘ceA-r"t I would like to request a modification to the Town of Pittsboro's NPDES permit NC0020354. The request is to allow for an alternate placement of our effluent composite sampler from its current location at the bottom of the cascade post aerator, to a point just upstream and after the UV system. The current location does not provide a representative sample of both effluents to Robeson Creek and our reclaimed water distribution system. Our current reclaimed water permit allows us to use the NPDES permit -required samples to satisfy the reclaimed permit requirements. When the reclaimed water pump is running, there is very little water going down the cascade aerator and the composite sampler is pulling from the very bottom of this channel. Our current location/sampling method is contradictory to proper sampling protocol and has a tendency to collect effluent that is not representative of our discharge to Robeson Creek. Mandy Hall, WWTP Consultant of the Raleigh Regional Office has recently visited our facility to review our sampling techniques. If you have further questions, please contact Ms. Hall at (919) 791-4254 or myself at (919) 548- 2444. Thank you for your consideration. Sincerely, Randy Heard Town of Pittsboro Wastewater Superintendent n Fr1-.. rt.. / ,..,, r '9 1.F° ',.'").. 1 zz, t 1 i rifil r,-,) MT-- • • *-- ---- ----Ipj JUN 6 2011 D EINFP::\NATE RTTRL POINT SOURCE BRANCH CHARTERED 1787 HEARING OFFICER REPORT for the Issuance of NPDES Permit NC0020354 Town of Pittsboro, NC Pittsboro Wastewater Treatment Plant This report is presented to the Director of the North Carolina Division of Water Quality. INTRODUCTION On February 17, 2011, public notices were published in the Sanford Herald and the Chatham News to announce a public hearing on the draft NPDES permit renewal/expansion for the Town of Pittsboro WWTP. The plant is currently permitted for 0.75 MGD with a discharge to Robeson Creek. The town plans to construct a new 3.22 MGD facility, utilizing the existing 0.75 MGD outfall and a proposed 2.47 MGD outfall into the Haw River. Both Robeson Creek and the Haw River are classified as WS-IV NSW within the Cape Fear River Basin. The public hearing was held in Pittsboro, NC on March 29, 2011. All written and oral comments became part of the public record. The official record was closed after the hearing. This Hearing Officer Report summarizes the major issues raised through the public hearing process, as well as the hearing officer recommendations for the NPDES Permit. The Division must take final action on these recommendations by June 27, 2011. FACILITY BACKGROUND The Town of Pittsboro presently operates an extended aeration 0.75 MGD wastewater treatment plant that discharges into Robeson Creek. This creek is tributary to Jordan Lake, flowing into the lake forming one of its northwest arms. Flows are so low that it may be considered a zero -flow stream for wastewater permitting purposes. Algal blooms have been observed within this arm during recenlyears and this reach of the stream has been placed on • the state's 303(d) list for chlorophyll -a. The causative pollutant is phosphorous. Robeson Creek is subject to a Total Maximum Daily Load (TMDL) for total phosphorous (TP). This TMDL limits future expansions to Robeson Creek. Since future expansion in Robeson Creek was not feasible, the Town evaluated other alternatives and ultimately selected a new discharge to the Haw River, which is subject to the Jordan Lake nutrient TMDL. A final environmental impact statement (EIS) for the proposed expansion was approved by DENR in a Record of Decision (ROD) dated March 29, 2010. The EIS addresses the alternatives considered for wastewater disposal, treatment plant site alternatives and wastewater conveyance alternatives. The draft permit addresses the need for wastewater treatment for a growing population. Additionally, the proposed new wastewater treatment facility will enable the town to comply with its TMDL for phosphorus in Robeson Creek, as well as the Jordan Lake total nitrogen (TN) and TP TMDL for its proposed Haw River outfall. The TMDL for Robeson Creek sets a seasonal waste Toad allocation of 146 Kg (322 lb) for TP to the Pittsboro WWTP from April through October. In addition, a nutrient TMDL was developed Page 1 for Jordan Lake. Pittsboro was given a total waste load allocation of 27,514 pounds per year TN and 3,731 pounds per year TP delivered at the lake. Transport factors for TN are 76% at Robeson Creek and 99% for the Haw River US 64 bridge outfall. For TP the transport factors are 82% for Robeson Creek and 99% for the Haw River US 64 site. PUBLIC RECORD Approximately 50 people attended the public hearing which was held by the Division on March 29, 2011. Twenty-one (21) attendees provided oral comments. Those opposed to the issuance of the permit included members of the Haw River Assembly and the Carolina Canoe Club. Comments in opposition of the permit are discussed below. At least seven persons spoke in support of issuing the permit. These included the chairman of the Chatham County Board of Commissioners, who reported unanimous support of the board for this project. The Mayor of Pittsboro also expressed support. Those in favor spoke of need for infrastructure, economic growth, and job creation. In addition, it was asserted that the need for a better quality wastewater effluent would be provided by the new facility's superior wastewater treatment technology. The Division received notice from U.S. EPA Region IV on October 7, 2010 that they had no comments regarding the draft permit. Listed below are the major objections raised in written comments and the comments received at the public hearing, and the Division staff responses. Appendix A contains a list of speakers and submitted written comments. Major Comments and DWQ Responses .1. Comment: Members of the Carolina Canoe Club and others that use the Haw River for paddling commented that the location of the new outfall on the Haw River at US Highway 64 was a bad choice, because it is a canoe access site with significant recreational use. A visible outfall pipe would be an eyesore to paddlers, and produce a foul odor. There were also many comments on potential human health impacts to recreational users who may come into contact with treated wastewater in the river. Response: The Haw River was recognized by the Division as the best alternative to receive the expanded discharge. The alternatives analysis in the EIS considered other locations for the new outfall. Expansion into Robeson Creek was not feasible, due to its low assimilative capacity and its TMDL limit for phosphorus. Based on water quality modeling, the recommendation was made to avoid a discharge on the Haw below US-64 or below Jordan Dam. ,Other alternatives, such as a direct discharge into Jordan Lake or the Cape Fear River below Jordan Dam, were more costly and would not provide the best wastewater assimilation. The selected location received a more favorable environmental ranking than other proposed outfall locations. In addition, the effluent will be reuse quality, which meets all water quality standards to protect human health for discharges to WS-IV classified waters. Page 2 2. Comment: Impacts to endangered species such as mussels and the Cape Fear Shiner were not properly addressed. Response: Impacts to endangered species were considered during the development of the final environmental impact statement (EIS), as approved by the Record of Decision/Statement of Findings (ROD). Buffers along the Haw River were set up to preserve priority habitats, and the discharge force main will not cross any waters designated as a critical habitat for the Cape Fear Shiner. A conclusion of the EIS was that endangered species would not be significantly affected by the proposed project. The draft permit includes a requirement for quarterly effluent toxicity testing using the water flea, Ceriodaphnia Dubia, which has been shown to be a protective surrogate test organism for the Cape Fear Shiner. 3. Comment: The design flow of the proposed treatment facility not justified. Response: Design flow was also considered during the development of the EIS. Flow projections were based on a 20-year planning horizon, which accounted for population growth and associated commercial/industrial growth for the Town of Pittsboro and areas within its ETJ. Again, the Division supports the findings of the EIS, as approved in the ROD. 4. Comment: The permit should contain 3/week upstream/downstream monitoring, with no waiver for coalition membership. Response: As a member of the Upper Cape Fear River Coalition, the Town currently operates under a waiver for instream sampling. The Division generally supports coalition monitoring, because monitoring data obtained by a monitoring coalition is of higher quality than that obtained from individual permittees. In addition, coalition monitoring provides better coverage of the river basin, and produces more usable data about the watershed as a whole. However, the Division recognizes that supplemental monitoring downstream of the proposed Haw River outfall may provide valuable data. 5. Comment: The plant should have redundancy of wastewater treatment components. Response: The Town must obtain an authorization to construct (ATC) for the new treatment facility. The ATC will require dual train treatment, in which every major treatment component will have a backup. In addition, a backup emergency generator must be provided in the event of a power failure. The Division therefore believes that the plant will have adequate redundancy. 6. Comment: Nutrient trading should not be allowed if it results in higher nutrient loadings in this effluent. The permittee should not be able to profit by selling unused allocation. Response: Jordan Lake has a TMDL for nutrients (total nitrogen and total phosphorus). Although transfer of nutrient allocations may be allowed by the Jordan Lake rules, there can be no overall net increase in nutrient loading into Jordan Lake. Although the TMDL was fashioned to protect the entire lake, and not the section of the Haw River near the proposed outfall, no adverse nutrient -related impacts are expected from a well-treated wastewater discharge into a free -flowing river. Further, it is very unlikely that the Town of Pittsboro would find it advantageous to sell nutrient allocations. Page 3 7. Comment: Wastewater reuse should be pursued more aggressively. Response: The alternative of wastewater reuse was considered in the EIS. Presently, both the Town and 3M Company have wastewater reuse permits from the Division to use Pittsboro's • treated effluent. In addition, the Town presently has a 500,000-gallon capacity elevated storage tank for reuse water, for potential future uses. The town will utilize reuse -quality wastewater for irrigation and non -potable uses to the extent possible 8. Comment The effluent pH limits should be changed from 6.0 to 9.0, to 6.0 to 8.0. Response: The Division has no technical justification for requiring any pH limits other a range of 6.0 to 9.0. This range is consistent with NC surface water quality standards for discharges into freshwater. HEARING OFFICER RECOMMENDATIONS Based on review of the public record including written/oral comments received during the public hearing process, I recommend to the Division Director that the 2011 Draft NPDES Permit NC0020354 for the Town of Pittsboro be revised as follows: 1. Many of the commenters were people who canoe and kayak on the Haw River and put their crafts in at the site of the proposed ouffall. They expressed concern regarding body contact with the treated effluent. The Town of Pittsboro intends to treat its wastewater to reuse water quality standards. Therefore, as an extra measure of safety to the public, I recommend that ouffall 002 permit limits for fecal coliform be modified to the reuse water quality standards of 14 per 100 mL as a monthly average and 25 per 100 mL as a weekly average. 2. As a member of the Upper Cape Fear River Basin monitoring coalition, the Town of Pittsboro is exempt from performing instream sampling. To demonstrate that the effluent discharge is not having a negative impact on the water quality of the Haw River, I recommend including outfall 002 upstream and downstream monitoring for fecal coliform at a frequency of 3/week in the months of June through September and 1/week the remainder of the year. In addition to the recommended permit revisions, I recommend the following: 1. The ouffall pipe from the treatment plant to the river is approximately 4.4 miles long and initial flows will most likely be very low. These conditions can create low dissolved oxygen and odors. To address this, as part of the Authorization to Construct, the Division's Construction Grants and Loans Section should require the outfall to include post aeration to increase dissolved oxygen prior to discharge into the river, for odor control and to be more aesthetically pleasing. Page 4 2. The results of monitoring performed for NPDES compliance are public record. In -order to make it easy for the public to access the results, I recommend that the Town of Pittsboro make the results of instream and effluent fecal coliform monitoring readily available by posting them as soon as possible on the Town's website. The results would not be "real time" since the fecal coliform sampling method requires a 24-hour incubation period, but it would allow those who are considering recreational use of the river to confirm the compliance history, note any trends, and make an informed decision on whether or not to get into the river. The Town should consider instream monitoring prior to the outfall construction in order to have baseline results for comparison. The implementation of this recommendation should be at the option of the Town. c-1/171 I a, a o tt Deborah Gore, Hearing Officer Date APPENDICES A. Draft Permit B. Announcement of Public Hearing C. Public Hearing Registration Sheet D. List of Speakers at the Public Hearing and Submitted Written Comments • f Page 5 A7A NCDENR (ec-V North Carolina Department of Environment and Natural Resources 94 Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director Memorandum To: Coleen Sullinsp,- Thru: Matt Matthews/Jeff Poupart From: Tom Belnick `T U Date: November 12, 2010 Subject: Request for Public Hearing/Pittsboro NC0020354 Dee Freeman Secretary NPDES has drafted a major modification for the Town of Pittsboro WWTP, which provides for expansion from 0.75 to 3.22 MGD. This proposal retains the original Outfall 001 permitted flow of 0.75 MGD to Robeson Creek and adds a new Outfall 002 with permitted flow of 2.47 MGD to the Haw River. The discharge to Robeson Creek is subject to a TP TMDL, and the combined discharge is subject to Jordan Lake Rules. This proposed expansion was subject to a SEPA EIS, and a draft ROD was issued on 3/29/2010. The draft permit modification was public noticed in the Sanford Herald on 10/1/2010, and this newspaper is a daily with general circulation in the subject area. NPDES received comments on the proposed permit modification from five (5) commenters, including two (2) requesting public hearing. A summary of comments is attached. Substantive comments were provided by Elaine Chiosso, Executive Director Haw River Assembly/Haw Riverkeeper. Ms Chiosso questioned several aspects of the SEPA EIS (e.g., threatened/endangered species, population projections, alternatives analysis, cumulative/secondary impacts). Ms Chiosso originally requested a 30-day extension to the public comment period, which was denied. NPDES believes the SEPA EIS and subsequent ROD adequately address the issues raised by the Riverkeeper and recommends against a public hearing. Please let us know if you concur or need additional information. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Localion: 512 N. Salisbury Si Raleigh. North Carolina 27604 Phone: 919-807-6300 FAX: 919-807-64921 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity t Affirmative Action Employer One NorthCarolina )Vatlliaij 47A NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary MEMORANDUM To: From: September 29, 2010 Michael L. Douglas, P. E. DEH / PWS Section Regional Engineer Raleigh Regional Office Gil Vinzani DWQ / NPDES Program Raleigh Office Subject: Review of Modified Draft NPDES Permit NC00020354 Pittsboro WWTP, Chatham County Please use a printed copy of this form to indicate your agency's position or viewpoint on this draft permit and return to me by October 15, 2010. If you have any questions on the modified permit, please contact me at telephone number (919) 807-6395 or via e-mail at gil.vinzani@ncdenr.gov. Thank you. RESPONSE: (Check one) Signed Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality standards. Concurs with issuance of this permit, provided the following conditions are met: Opposes the issuance of this permit, based on reasons stated below, or attached: 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919-807-64951 Customer Service: 1-877-623-6748 Internet: http: / h2o.enr.state.nc.us / An Equal Opportunity \ Affirmative Action Employer Date: G 0/57 0 OCT 72010 DENR-WATER QUALITY POINT SOURCE BRANCH Nne orthCarolina Naturally Affidavit of Publication • Lee County .North Carolina Holly Hight, Classified Advertising Represents ive of The Sanford Herald, a • Newspaper published in Lee County in the state of North Carolina; being duly - .sworn, deposes and says: that the attached advertisement of notice, in the ' •action entitled. ' ,R)dic • was duly -published in. the aforesaid newspaper one a week for with the issue dated the day of (DC and endin,g with the issue dated the j_,•. day of Holly Hight, sifted Adv sing Representative Received of/0 WE) R/DJ G the above publication. By: Sworn to and Notary 3�CCS2.. actOCh , the cost of scribedbefo 'se, this I day of or tober- curikivt My CommnissionFxpires:- _. , 2o) 0 Public Notice North Carolina Environmen- tal Management Commission/NPDE. init 1617 Mail Service Center Raleigh, NC 27699-1617 Notice of Intent to Issue a NPDES Wastewater Permit The North Carolina Environ- mental Management Commission proposes to is- sue 3 NPDES wastewater discharge-par:sato the per- sons) listed below. Written comments regarding the proposed permit will be accepted until 30 days after the publish date of this no- tice. The Director of the NC Division of Water Quality (DWQ) may hold a public hearing should there be a significant degree of public interest. Please mall com- ments-amilvrirdui azt:on re- quests to DWQ at the above address. Interested persons may visit the DWQ at 512 N. Salisbury Street, Raleigh, NC to review information on file. Additional information on NPDES permits and this notice may be found on our website: www.ncwaterquai- ity.org, or by calling (919) 807-6304. The Town of Pittsboro has applied for a permit modifi- cation to permit NC0020354 to expand its wastewater discharge in Chatham County. An additional 2.47 MGD outfall to the Haw River is requested, within the Cape Fear River Basin. Hoobs Upchurch Associates August 12, 2010 Gil Vinzani NPDES Program, DWQ RE: Pittsboro NPDES application NPDES NC0088943 Response to comments to application dated July 7, 2010 Commenting letter attached Mr Vinzani, Herein we offer our responses to your comments and requests for clairification of the NPDES permit application for the proposed 3.22 MGD Pittsboro WWTP. Thank you. 1 Decommisioning: The existing Pittsboro WWTP will operate until the new plant is ready to accept flow. Transition between the two plants will be a matter of diverting flow incrementally from the old plant to the new one. Since the new plant can treat more flow than the existing plant, the new facility will accept all of the wastewater flow once it becomes seeded and acclimated which should take approximately 6-8 weeks from start to finish. There will be constructed a new bar screen, grit removal, and influent pump station rated for a peak flow of 5700 GPM located adjacent to the existing headworks to make use of the existing collection system. These components will be built as part of the capitol project to build the first half of the new plant. Once complete, the new plant will be seeded from the existing one and gently cut over by routing part of the influent to the new headworks. The new plant, once tuned and running, will accept all of the flow. Then the old plant will be shutdown, pumped out, and cleaned. From that point, the existing structures will be assessed for their applicability for future possible use as sludge digesters. If the plant components are not applicable because of their age and condition then they will be demolished. The existing new equalization basin will be used for holding sludge for haul disposal during the early years while it is not economically feasible to operate a sludge digester. The sludge handling building will be preserved for future use. It is not the intent of the town to have parallel NPDES permits and will abide by the permit governing which ever plant is in operation. A 12 week overlap should be adequate for establishing the new plant T: 91u 686.1212 I F. ils 5,q 1145 I 8262-201 MARKET STREET I WILM!NCcTON, NC 28411 i WWW.HOBRSUPCHURCH.COM PERFORMANCE H DESIGN Town of Pittsboro NPDES Application Comments 8-12-2010 , 2 The existing outfall into Robeson creek will continue to be used. It has never had a problem and will be a simple task to conduct treated effluent from the new plant to the existing parshall meter and step aerator which subsequently flows to the outfall in Robeson Creek. 3. Randy Heard (Pittsboro, Wastewater Treatment Plant Superintendent) stated that Pittsboro has a letter from DWQ attesting that their pretreatment program is inactive because they currently have NO SIUs attached to their collection system. There may be some in the future, but for now they have none. 4 The New Pittsboro 3.22 MGD plant treatment components will be comprised of: 1 ea Influent Bar Screen, (rated for 5700 GPM peak flow) 1 ea Influent Grit removal, (rated for 5700 GPM peak flow) 1 ea Influent Pump Station, (rated for 5700 GPM peak flow) 4 ea Anaerobic Basin, (810,000 GPD) 4 ea Oxidation Ditch with Anoxic Zone, (810,000 GPD) 4 ea Secondary Clarifiers, (810,000 GPD) 1 ea WAS/RAS Pump building returning sludge to Anaerobic Basins and Oxidation Ditchs at 3.22 MGD 4 ea Filters / Denitrification Filters, (810,000 GPD) 1 ea Sludge Storage Basin. 1 ea Treated WasteWater Pump Station that will convey water to 1) Robeson Creek, 2) Haw River, and 3) Reuse users. 2 ea Discharge structures 1) in Robeson Creek 0.75MGD; 2) in Haw River at 2.47 MGD Sincerely, Barry King, PE Hobbs, Upchurch, & Associates, P.A. ATA, NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary July 7, 2010 Mr. William Terry Town Manager Town of Pittsboro P. O. Box 759 Pittsboro, NC 27312 Subject: Application for NPDES Permit Permit No. NC0088943 Town of Pittsboro Chatham County Dear Mr. Terry: Division personnel have conducted a preliminary review of your application for the subject permit. We have the following questions regarding this application. 1. Please discuss the decommissioning of the existing facility, currently permitted under NC0020354. How will this plant be phased out? What is the timing relative to the start-up of the new facility? 2. Will the existing outfall 001 be used for the 0.75 MGD from the new facility to Robeson Creek? Will any other existing treatment components be used, including the existing sludge facilities? 3. The application does not contain any information regarding significant industrial users (Sills). Will the new facility treat only domestic sewage? 4. Please provide a detailed listing of the treatment components of the proposed facility. Thank you in advance for your response. Should you have any questions, please contact me at 919-807- 6395, or by E-mail at gil.vinzani@ncdenr.gov. Sincerely, Gil Vinzani, P NPDES Program cc: Hobbs, Upchurch and Associates, P.A. / Adam Kiker, PE Central Files Raleigh Regional Office / Danny Smith NPDES Files 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-6300 i FAX: 919.807-64921 Customer Service: 1-877-623-6748 Interne!: www ncwaierquality.org An Equal opportunity't Alternative Action Employer One NorthCarolina ;VatWally Vinzani, Gil From: Mckay, James Sent: Wednesday, July 07, 2010 1:08 PM To: Vinzani, Gil Subject: FW: Low -flow characteristics for Haw River at U.S. 64...Re: Flow estimate for;Haw River at US 64 bridge Jim McKay, Environmental Engineer NC DENR / Division of Water Quality / Surface Water Protection Section Point Source Branch 1617 Mail Service Center, Raleigh, NC 27699-1617 919/807-6404 (work); 919/807-6495 (fax) **Please note, my email address has changed to James.McKay@ncdenr.gov 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: John C Weaver [mailto:jcweaver@usgs.gov] Sent: Tuesday, June 10, 2008 1:36 PM To: James Mckay Cc: John C Weaver Subject: Low -flow characteristics for Haw River at U.S. 64...Re: Flow estimate for;Haw River at US 64 bridge Jim, In response to your inquiry about the low -flow characteristics (7Q10, 30Q2) for Haw River at U.S. Highway 64 near Pittsboro in Chatham County (station id 0209699980, drainage area 1,296 sqmi), the following information is provided: A check of the low -flow files here at the USGS North Carolina Water Science Center does not show a previous determination of low -flow characteristics for your point of interest. In the absence of site -specific discharge records sufficient for a low -flow analyses, low -flow estimates are assessed by determining a range of low -flow yields (expressed as flow per square mile drainage area, or cfsm) at nearby locations where estimates have previously been determined. Your point of interest is downstream and upstream of one active and one discontinued streamgaging stations, respectively. For this request, the flow characteristics at the upstream active streamgage (station id 02096960, drainage area 1,275 sqmi) can be considered applicable at your point of interest considering the small change in drainage area between the two locations. USGS Sta. 02096960 Haw River near Bynum, POR October 1973 to current, drainage area 1,275 sqmi 7010 = 71.8 cfs (equivalent to 0.056 cfsm) 3002 = 159 cfs (equivalent to 0.125 cfsm) Qavg = 1,240 cfs (equivalent to 0.97 cfsm) Based on period during 1974-2007 climatic years Note: The climatic year is the standard annual period used for low -flow analyses at continuous -record gaging stations. It runs from April 1 through March 31 and is designated by the year in which the period begins. For example, the 2007 climatic year is from April 1, 2007, through March 31, 2008. 1 Please note a portion of the record within the above period of analysis contains discharge data (from October 2007 through March 2008) that is considered provisional and subject to revision pending further review and finalization of discharge records. A final comment...you identified coordinates in your email as the location for proposed Town of Pittsboro discharge point. My examination of this location on the topo map indicates it is within the impounded reach of Haw River (Jordan Lake). Please be aware the above estimates at U.S. 64 cannot be pro -rated further downstream because of the transition from riverine to impounded flow conditions. While there is flow through the impounded reach, the USGS does not estimate the 7Q10 in these types of reaches because the effects of storage and circulation are not accounted for using the techniques used to estimate low -flow characteristics. Hope this information is helpful. Thank you. Curtis Weaver J. Curtis Weaver, Hydrologist, PE USGS North Carolina Water Science Center 3916 Sunset Ridge Road Raleigh, NC 27607 Telephone: (919) 571-4043 11 Fax: (919) 571-4041 E-mail address -- Icweaver©usgs.gov Internet address -- http://nc.water.usgs.Qov/ *********************************************************************** James Mckay <James.McKay@ncmail.net> 06/06/2008 04:11 PM Curtis: To John C Weaver <jcweaver@usas.aov> cc Subject Flow estimate for Haw River at US 64 bridge Could you please give me flow estimates for the Haw river just downstream of the US 64 bridge? The approximate coordinates for a proposed Town of Pittsboro discharge are 35 deg. 41' 55" Lat. and 79 deg. 04' 60" Long. I am working on another set of speculative limits for them. Thanks for your help, Jim McKay Environmental Engineer Eastern NPDES Program NCDWQ (919) 733-5083, ext. 595 2 Pittsboro Spec Limits Nutrient Loading Data: TN allocation at Jordan Lake = TP allocation at Jordan Lake = WLA for Robeson Creek = Total WWTP capacity = Outfall 001 to Robeson Creek = Outfall 002 to Haw River = TN transport factor for Robeson Creek = TP transport factor for Robeson Creek = TN transport factor for Haw River = TP transport factor for Haw River = Trial & error Calculations Total Nitrogen Operating Concentration, mg/L 2.9975 Total Phosphorus, mg/L 0.42187 27,514 Ib/ year 3,731 Ib/ year 322 lb TP April through October 3.22 mgd 0.75 mgd 2.47 mgd 76% 82% 99% 99% TN discharged at 001: TN Delivered to Jordan from Robeson Creek : Total TN delivered to Jordan: TP discharged at 001 April through October: TP discharged at 001 November through March: TP Delivered to Jordan from Robeson Creek: Total Phosphorus Delivered to Jordan: 6,843.52 Ib/ year TN discharged at 002: 22,537.98 Ib/ year TN Delivered to Jordan 5,201.07 Ib/ year from Haw River : 22,312.60 Ib/ year 27,513.68 Ib/ year Total TP discharged at 002: 322.00 pounds TP delivered to Jordan from Haw River: 398.46 pounds 590.78 Ib/ year Total 3,731.07 Ib/ year 3,172.01 Ib/ year 3,140.29 Ib/ year C.2 (1) Comparison ofHaly River and Jordsatr Lake Discharge Alternate es (Cont'd) Common Discharge Segment Length= 9,129 I..l' (1.73 miles) Haw River Discharge Main Total Length= 23,000 LF (4.36 miles) (Preferred Alternative) Jordan Lake Discharge Main Total Length= 34,584 LF (6.6 miles) ers (*lace Figure 9. Town of Pittsboro WWTP and Potential Discharge Locations for the balance of 2.47 MGD [Haw River (US-64 Bridge) or Jordan Lake] Town of Pittsboro, NC ProposedWastewater Treatment Plant and Discharger into Robeson Creek and the Haw River Prcp isa,1 h,: Hobbs, Upchurch & Associates, P.A. Sr.j-r, rsh r ';::i 41 C , Discharge Alternatives (Com'cl) C.2 (2) Preferred Additional Discharge Site: Haw River (US-64 Bridge) The 2.47 MGD balance will be discharged at the Haw River US-64 bridge location, while maintaining the current discharge of 0.75 MGD into Robeson Creek. Nutrient Allocations A guiding characteristic in selecting or proposing a wastewater discharge site is the associated allotted nutrient loading. With the anticipated future service requirements that will be placed on the Pittsboro wastewater system, the plant capabilities at maximum flow must be taken into consideration now. The main impact to water quality in Jordan Lake is algae growth. Excessive algae growth spawns eutrophication of the lake and unpleasant odors in water supplies. Since algae grow in warm water with the appropriate nutrient supply, the only way to effectively stop eutrophication is to remove or prohibit the nutrients in the water before the algae cycle starts. To this end, the NCDENR has established allocations of nutrients to communities along the Haw River for planning their developmental futures. With these allocations towns can choose the amount of development or treatment that is right for them, knowing that they may not go beyond the established mass of nutrients that may be discharged. Another facet of the design process is the assimilative capability of the river for removing nutrients from the effluent before reaching the lake. Table 13 was developed from the Speculative Limits provided by the DWQ NPDES Unit in July 25th 2008 (See Exhibit G-2). The table shows the nutrient loading allocated to the Pittsboro community and modeled total discharges at various locations in order to achieve that allocation. Different surface water discharge sites have different assimilative capabilities and the net discharge will vary by the percent listed in the table. Fundamentally, the more surface area, oxygen, and traveling time that is available to the treated wastewater, the more the nutrients that are removed from the water. For discharging directly to the lake there is no assimilative consideration and the net discharge equals the allotted discharge. Town of Pittsboro, NC Proposed Wastewater Treatment Plant and Discharges lnto Robeson Creek and the Haw River Prcp.ircd hy Hobbs, Upchurch & Associates, P.A. Sc. p*c^.)hcr '11(') 42 .. L)ist!Zar4 e Alternatives (Cosit 'c/) C.2 (2) Preferred Discharge Alternative: Haw River (US-64 Bride) Table 13. Nutrients Allocations for Potential Discharge Sites: Haw River and Jordan Lake Nutrient Robeson Creek Haw River at 64 Bridge Jordan Lake Discharge , Mass (lbs) Transport Factor Mass (lbs) Transport Factor Mass (lbs) Transport Factor Total Nitrogen 5,153 77% 22,361 99% 27,514 100% Total Phosphorus 449 82% 1,807 99% 3,731 100% Source: Nutrient poundage is based on the Speculative Limits provided by DWQ — NPDES Unit in July 2008 (Exhibit G-2). Discharge Location Alternatives- Conclusions The (US-64) discharge is the location of least overall impact based on: ■ The US 64 bridge site would provide one mile of natural turbulent mixing (enhanced assimilation) upstream of Jordan Lake. The location offers capacity for turbulent mixing and re -oxygenation, due to abundant rocky rapids upstream of pool level in Jordan Lake thus providing abundant oxygen for any residual BOD in the effluent stream. ■ The US 64 bridge site would have negligible effect on forest resources as opposed to the lake discharge site which would require crossing 0.5 miles of a natural heavily forested area (See discussion in Exhibit D-2). • A discharge in Jordan Lake would affect more recreational users since more people swim in the lake as opposed to the river (Michael Hosey, US Corp of Engineers, personal communication, November 2006). • Discharging into Jordan Lake provides little of what is needed to completely degrade the wastewater stream. 1) Little mixing occurs on the slow moving lake bottom with only the energy of the diffuser to move the water. 2) In summer the established thermocline will further isolate the discharge stream from oxygen available at the Lake's surface further causing oxygen deficits. 3) During periods of low flow the lake can have stagnant zones; therefore, the nutrients in the lake would be more concentrated in regions close to the diffuser adding to the potential for excessive algae growth as observed in the mouth of Robeson Creek. Town of Pittsboro, NC Proposed wastewater Treatment Plant and Discharges Into Robeson Creek and the Haw River Para by Hobbs, Upchurch & Associates, P.A. mher 2f)09 43 PITTSBORO Pritsboro WWTP Proposed 16-Acre Site Improvements Center Township FLOOD ZONE Area (acres) % of County Area AE 45789 10.1 AERV 555 0.1 SHADED X 262 0.1 SUM OF AREAS 46605 10.3 CHATHAM COUNTY (acres) 454311 Route A Proposed 23,000 LF Discharge Main N Hobbs, Upchurch, & Associates, P_4. Consulting Engineers 14878 US Huy. 17 Ste. S Hampstead NC, 28443 Legend b.,lra r T,.n,,.P. 'acels - MOP . Oad,a,e Pies a_ ras Fiver O sr>p. .roan Lou ovr>oe — Reed eee..*. flood Zen,, - PE — 5,2 1 • New (tope Township Proposed Jordan Lake Discharge Town of Pittsboro Chatham County, NC Floodplains Figure 3. Floodplains at the Pittsboro WWTP and along the Haw River and Jordan Lake Discharge Routes Town of Pittsboro, NC Proposed Wastewater Treatment Plant- Evaluation of Discharge Alternatives I`r:I+.itcdi by Hobbs, Upchurch & Associates, P.A..\n ,i - I: - Exhibit D-2 6 Table 7 CAPE FEAR Subbasin 03-06-04 AU Number Classification Length/Area Description Aquatic Life Assessment Year/ AL Rating Station Result Parameter % Exc Recreation Assessment REC Rating Station Result Stressors Sources Marys Creek 16-26 C NSW 10.1 FW Miles S From source to Haw River BB377 GF 2003 BB377 NR 2003 BB377 GF 2000 ND ;•••,; '.•1.;;11"-• Habitat Degradation ,,•••• ,, • -.• Pokeberry Creek 16-37 WS-IV NS From source to Haw River 8.0 FW Miles BB320 GF 2003 BB320 GF 2003 Robeson Creek ND Habitat Degradation Land Clearing 16-38-(3)1) WS-IV NS 16.7 FW Acres NR BL I I NCE Chlor a 10C Pittsboro Lake ND Chlorophyll a Impervious Surfac' Chlorophyll a WWTP NPDES 6-38-(3)c WS-1V NS 2.4 FW Miles From Pittsboro Lake to UT across from SR 1951 BB12 F 2001 BB16 F 2001 BB45 F 2001 ND Habitat Degradation ND land app site Habitat Degradation Impervious Surfac. Habitat Degradation WWTP NPDES 16-38-(3)d WS-1V NS 3.1 FW Miles S From UT across from SR 1951 to Jordan Reservoir BB189 GF 2001 BB189 F 2001 131'16 G 2003 ND Habitat Degradation Terrells Creek (Ferrells Creek) (North Side Haw River) 16-32 WS-IV NS 7.6 FW Miles S From source to Haw River BF43 G 2003 ND Terrells Creek (South Side Haw River) 16-31-(2.5) WS-IV NS From Cattail Creek to Haw River 6.7 FW Miles $ BB158 GF 2003 BB158 F 2003 BF9 E 2003 ND Low Dissolved Oxygen CAPE FEAR Subbasin 03-06-04 Table 7 CAPE FEAR Subbasin 03-06-04 AU Number Classification Length/Area Description HAW RIVER I6-(28.5) WS-IV NS 11.4 FW Miles From a point 0.4 miles downstream of Cane Creek (South side of Haw River) to a point 0.4 miles downstream of Brooks Branch Aquatic Life Assessment Recreation Assessment Year/ AL Rating Station Result Parameter % Exc REC Rating Station Result S BA135 NCE S BA135 NCE l. Stressors Sources • ‘: 16-(36.3) WS-1V NS 0.5 FW Miles From a point 0.4 miles downstream of Brooks Branch to Pittsboro water supply intake (located 0.3 miles upstream of Pokeberry Creek) I 6-(36.7) WS-IV NS S BA139 NCE 3.8 FW Miles From Pittsboro water supply intake to a point 0.5 mile downstream of U.S. Hw. 64 s BB443 G 2002 S BAI39 NCE Ktp4A441. 05 03 0002 I 6-(37.3) WS-IV NS 53.2 FW Acres From a point 0.5 mile downstream of US Hwy 64 to approximately 1.0 mile below US Hwy 64 1 BLI CE Chlora 33 BLI CE High pH 23.5 ND High pH High pH High pH High pH Chlorophyll a Chlorophyll a Chlorophyll a Chlorophyll a Agriculture Impervious Surfac. MS4 NPDES WWTP NPDES Agriculture Impervious Surfac. MS4 NPDES WWTP NPDES Haw River (B. Everett Jordan Lake below normal pool elevatio AT4141-5MITIfifF,Wilit ''-i4.;:1144Fgglarf. 16137.5) WS-IV&B 1,392.3 FW Acres From approximately 1.0 mile below U.S. Hwy. 64 to dam at B. Everett Jordan Lake) 1 BA150 CE Chlora BLI CE Chlora 33 BLI CE High pH 23.5 24 High pH High pH High pH High pH Chlorophyll a Chlorophyll a Chlorophyll a Chlorophyll a Agriculture Impervious Surfac. MS4 NPDES WWTP NPDES Agriculture Impervious Surfac' MS4 NPDES WWTP NPDES CAPE FEAR Subbasin 03-06-09 Vinzani, Gil From: Myers.Pamala@epamail.epa.gov Sent: Thursday, October 07, 2010 4:32 PM To: Vinzani, Gil Cc: myers.pamala@epa.gov Subject: NC0020354 Pittsboro draft permit - review complete. Mr. Vinzani (Gil), Once I located the application notebook here in our office I found the answers to my questions about the draft permit. EPA has no formal comments at this time. If substantial changes or edits are made to the draft permit please allow Region 4 to review them prior to final issuance. A copy of the standard conditions (Parts II, III, and IV) for our files may follow at your earliest convenience. If you require a more formal letter for your files, I will be happy to prepare one for you. Thank you. Pamala Myers Pamala Myers 404.562.9421 myers.pamala@epa.gov Environmental Engineer and Technical Advisor I Pollution Control and Implementation Branch Water Protection Division I Municipal and Industrial NPDES Section U.S. EPA, Region 4 161 Forsyth St. SW I Atlanta, GA 30303 ><((((°>'••..._•" -.... ---...,><((((°>s-....•. ..,.•"-'-...>< ((((°>`.. •.., �•.,.•"--.....><((((°> From: "Vinzani, Gil" <gil.vinzani@ncdenr.gov> To: Pamala Myers/R4/USEPA/US@EPA Date: 10/06/2010 04:56 PM Subject: RE: NC0020354 Pittsboro draft modification questions Hello, Pamala: 1 ' FACILITY NAME AND PERMIT NUMBER: Town of Pittsboro. NC0020354 PERMIT ACTION REQUESTED: RIVER BASIN: A.11. Description of Treatment a. What level of treatment are provided? Check all that apply. pc Primary := Secondary Advanced - Other. Describe: b. Indicate the following removal rates (as applicable): Design BOD5 removal or Design CBOD5 removal 85 % Design SS removal _,_ % Design P removal ..nor`.. •: " _ ..e:D:. % Design N removal FPorit^r a-:c Re:o:t % Other % c. What type of disinfection is used for the effluent from this outfall? If disinfection varies by season, please describe: Uv If disinfection is by chlorination is dechlorination used for this outfall? C Yes _ No Does the treatment plant have post aeration? E. Yes Z No A.12. Effluent Testing Information. All Applicants that discharge to waters of the US must provide effluent testing data for the following parameters. Provide the indicated effluent testing required by the permitting authority for each outfall through which effluent is discharged. Do not include information on combined sewer overflows in this section. All information reported must be based on data collected through analysis conducted using 40 CFR Part 136 methods. In addition, this data must comply with QAJDC requirements of 40 CFR Part 136 and other appropriate QA/QC requirements for standard methods for analytes not addressed by 40 CFR Part 136. At a minimum, effluent testing data must be based on at least three samples and must be no more than four and one half years apart Outfall number. PARAMETER MAXIMUM DAILY VALUE AVERAGE DAILY VALUE Value 1 Units Value Units Number of Samples pH (Minimum) s.u. pH (Maximum) ... _ s.u. Flow Rate .' _ _ .400 NIG1r CONTINUOUS Temperature (Winter) I C _ 14 Degrees C DAILY Temperature (Summer) 2 25 2iegrees C DAILY * For pH please report a minimum and a maximum daily value POLLUTANT MAXIMUM DAILY DISCHARGE AVERAGE DAILY DISCHARGE ANALYTICAL METHOD MUMDL Conc. Units Conc. Units Number of Samples CONVENTIONAL AND NON CONVENTIONAL COMPOUNDS BIOCHEMICAL OXYGEN DEMAND (Report one) BOD5 ., 2. .••a� . SM5210B CBOD5 FECAL COLIFORM 40C 20 2AlVeek SM92221.:: TOTAL SUSPENDED SOLIDS (TSS) 45 Mgr.' ;;-,g; l 3:...,., r' ee;{ c M2S44L! END OF PART A. REFER TO THE APPLICATION OVERVIEW (PAGE 1) TO DETERMINE WHICH OTfiER PARTS OF FORM 2A YOU MUST COMPLETE NPDES FORM 2A Additional Information FACILITY NAME AND PERMIT NUMBER: ,. Town of Pittsboro. NC0020354 PERMIT ACTION REQUESTED: T-7'4.1-!avvP1 RIVER BASIN: Cape Fear BASIC APPLICATION INFORMATION PART B. ADDITIONAL APPLICATION INFORMATION FOR APPLICANTS WITH A DESIGN FLOW GREATER THAN OR EQUAL TO 0.1 MGD (100,000 gallons per day). All applicants with a design flow rate >_ 0.1 MGD must answer questions B.1 through B.6. All others go to Part C (Certification). B.1. Inflow and Infiltration. Estimate the average number of gallons per day 5.000 GPD that flow into the treatment works from inflow and/or infiltration. are c:_ii ren: ;v `i orkino on our 2 u phase that should gc out to ;yid Briefly explain any steps underway or planned to minimize inflow and infiltration. We have had several projects to reoair cu'r'.'' crob'e . 'Ne in early 2011 B.2. Topographic Map. Attach to this application a topographic map of the area extending at least one mile beyond facility property boundaries. This map must show the outline of the facility and the following information. (You may submit more than one map if one map does not show the entire area.) a. The area surrounding the treatment plant, including all unit processes. b. The major pipes or other structures through which wastewater enters the treatment works and the pipes or other structures through which treated wastewater is discharged from the treatment plant. Include outfalls from bypass piping, if applicable. c. Each well where wastewater from the treatment plant is injected underground. d. Wells, springs, other surface water bodies, and drinking water wells that are: 1) within % mile of the property boundaries of the treatment works, and 2) listed in public record or otherwise known to the applicant e. Any areas where the sewage sludge produced by the treatment works is stored, treated, or disposed. f. If the treatment works receives waste that is classified as hazardous under the Resource Conservation and Recovery Act (RCRA) by truck, rail, or special pipe, show on the map where the hazardous waste enters the treatment works and where it is treated, stored, and/or disposed. B.3. Process Flow Diagram or Schematic. Provide a diagram showing the processes of the treatment plant, including all bypass piping and all backup power sources or redunancy in the system. Also provide a water balance showing all treatment units, including disinfection (e.g., chlorination and dechlorination). The water balance must show daily average flow rates at influent and discharge points and approximate daily flow rates between treatment units. Include a brief narrative description of the diagram. B.4. Operation/Maintenance Performed by Contractor(s). Are any operational or maintenance aspects (related to wastewater treatment and effluent quality) of the treatment works the responsibility of a contractor? L' Yes 21, No If yes, list the name, address, telephone number, and status of each contractor and describe the contractor's responsibilities (attach additional pages if necessary). Name: Mailing Address: Telephone Number. L____)____ Responsibilities of Contractor: B.S. Scheduled improvements and Schedules of Implementation. Provide information on any uncompleted implementation schedule or uncompleted plans for improvements that will affect the wastewater treatment, effluent quality, or design capacity of the treatment works. If the treatment works has several different implementation schedules or is planning several improvements, submit separate responses to question B.5 for each. (If none, go to question B.6.) a. List the outfall number (assigned in question A.9) for each outfall that is covered by this implementation schedule. b. Indicate whether the planned improvements or implementation schedule are required by local, State, or Federal agencies. ❑ Yes X No NPDES FORM 2A Additional Information 4 FACILITY NAME AND PERMIT NUMBER: Town of Pfttsboro. NC0020354 PERMIT ACTION REQUESTED: 'Renewal RIVER BASIN: Cape Fear c. If the answer to B.5.b is "Yes," briefly describe, including new maximum daily inflow rate (if applicable). d. Provide dates imposed by any compliance schedule or any actual dates of completion for the implementation steps listed below, as applicable. For improvements planned independently of local, State, or Federal agencies, indicate planned or actual completion dates, as applicable. Indicate dates as accurately as possible. Schedule Actual Completion Implementation Stage MM/DD/YYYY MM/DD/YYYY - Begin Construction / / / / - End Construction _ / / / / - Begin Discharge / / / / - Attain Operational Level / / / / e. Have appropriate permits/clearances concerning other Federal/State requirements been obtained? ❑ Yes 0 No Describe briefly: B.6. EFFLUENT TESTING DATA (GREATER THAN 0.1 MGD ONLY). Applicants that discharge to waters of the US must provide effluent testing data for the following parameters. Provide the indicated effluent testing required by the permitting authority for each outfall through which effluent is discharged. Do not include information on combine sewer overflows in this section. All information reported must be based on data collected through analysis conducted using 40 CFR Part 136 methods. In addition, this data must comply with QA/QC requirements of 40 CFR Part 136 and other appropriate QA/QC requirements for standard methods for analytes not addressed by 40 CFR Part 136. At a minimum effluent testing data must be based on at least three pollutant scans and must be no more than four and on -half years old. Outfall Number. POLLUTANT MAXIMUM DAILY DISCHARGE AVERAGE DAILY DISCHARGE ANALYTICAL METHOD MLJMDL Conc. Units Conc. Units Number of Samples CONVENTIONAL AND NON CONVENTIONAL COMPOUNDS AMMONIA (as N) 2.0 Mgll 0.3 Mgll 31week 4500 CHLORINE (TOTAL RESIDUAL, TRC) 28 Ugil <10 Ugil 3fweek sm4500c1 g DISSOLVED OXYGEN >6.0 Mg;? 7.0 Moll Daily Sm4500og TOTAL KJELDAHL NITROGEN (TKN) Monitor and report nlfa:! 2.5 Mg/! weekly Epa351. NITRATE PLUS NITRITE NITROGEN Monitor and report Mail 30.0 Ylg/i weekly Epa353.2 OIL and GREASE NA NA NA NA NA NA PHOSPHORUS (Total) 2.0 Mal; ;; ei! Weekly Sm4500pe TOTAL DISSOLVED SOLIDS (TDS) NA N NA NA NA NA OTHER END OF PART B. REFER TO THE APPLICATION OVERVIEW (PAGE 1) TO DETERMINE WHICH OTHER PARTS OF FORM 2A YOU MUST COMPLETE NPDES FORM 2A Additional Information FACILITY NAME AND PERMIT NUMBER: Town of Pittsboro. NC0020354 PERMIT ACTION REQUESTED: Ren..,Jva I RIVER BASIN: Cape Fear BASiC APPLICATION INFORMATION PART C. CERTIFICATION All applicants must complete the Certification Section. Refer to instructions to determine who is an officer for the purposes of this certification. All applicants must complete all applicable sections of Form 2A, as explained in the Application Overview. Indicate below which parts of Form 2A you have completed and are submitting. By signing this certification statement, applicants confirm that they have reviewed Form 2A and have completed all sections that apply to the facility for which this application is submitted. Indicate which parts of Form 2A you have completed and are submitting: Ei Basic Application information packet Supplemental Application Information packet: ++ Part D (Expanded Effluent Testing Data) Part E (Toxicity Testing: Biomonitoring Data) Part F (Industrial User Discharges and RCRA/CERCLA Wastes) Part G (Combined Sewer Systems) ALL APPLICANTS MUST COMPLETE THE FOLLOWING CERTIFICATION. I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Name and official title Jc r. Poteat. Puhiic'.":ork:3 a^d ! I litres Director Signature .. Telephone number (919) 542-2530 Date signed AO /Ad D Upon request of the permitting authority, you must submit any other information necessary to assure wastewater treatment practices at the treatment works or identify appropriate permitting requirements. SEND COMPLETED FORMS TO: NCDENR/ DWQ Attn: NPDES Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 !NPDES FORM 2A Additional information t. North Carolina Department of ALministraiacm Beverly Eaves Perdue, Governor Secretary Match 29,2010 Ms...Hannah Stallings 11:CDENR,. Water Quality 1017 Mail Service Center. Raleigh,,NC.27699-1617 Moses Careyi Re:. S.M.File.#1044:300 nt$;,rittAbOrP. 312 11110.1).wastewater#POIAMit-Plaxii,V413- dnal diSchatgeSIO Robeson Creek 4fid the gaw. River. Dear.Ms. Stallings: Theatove referenced.environmentalimpactinfOnnation has been reviewed through the:State.. Clearinghouse under the.proViAiOTAP).0.. 01.0rili.C4PlinaErwiron)zentat-PoliCy Ao. . . . . gotailitents were mado,by.aily•statenOCarAgencies-inthe course ofthis review. Therefore, no.:fiuthu- enVironmentatreyiew.action.on your-1:1_00s required for empli400.*itil the:, Act. Betttegards, .114s. Chry,S Baggett' .Statelnvironraental Review Clearinghouse ccRegi�n.J CDs .& 2 hard copies CDs MOilitigArldras: .Telepltime! 6)19)3077242$ L6Fylfpn 4 (IdOsi; ppi .Maii Servicetenter Fax (919)73-9571 116 Mstionis Stint Raltigh. NC 2169971301 Statc Couiter #5,1-01410 Ralcigh. NottlyCarotina -e-mallsiale.cfraiingbouse9tka.ncgov An Equal OppotiuniOffirmativeAclion Einployer rwA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Govemor Director March 29, 2010 To: Chrys Baggett, State Clearinghouse From: Hannah Stallings, NCDENR/Division of Water Quality Subject: Record of Decision for the proposed 3.22 MGD Pittsboro WWTP with dual discharges to Robeson Creek and the Haw River Dee Freeman Secretary The Division of Water Quality is submitting for State Clearinghouse review the enclosed ten copies of the Record of Decision for the subject project for a 30-day information only posting in the Environmental Bulletin. The Draft EIS was reviewed under SCH #10-E-430O-0140 and the Final EIS of the SCIMP was reviewed under SCH #10- E-4300-0290. Please publish this project in the Environmental Bulletin and circulate as appropriate. Contact me at 807-6434 if you have any questions. Thank You. Enclosures 1617 Mall Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919-807-64921 Customer Service:1-877-623.6748 Internet www.ncwaterquality.org - An Equal Opportunity 1 Affirmative Action Employer r lo°e Carolina Q�IfPQlly RECORD OF DECISION ENVIRONMENTAL IlVxPACT STATEMENT (EIS) WASTEWATER TREATMENT PLANT WITH DUAL DISCHARGES TO ROBESON CREEK AND THE HAW RIVER TOWN OF PITTSBORO, NORTH CAROLINA PREPARED BY THE: NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PLANNING SECTION DWQ#14115; DENR#1501 MARCH 29, 2010 CONTACT PERSON: HANNAH STALLINGS, DWQ SEPA COORDINATOR 4 An EIS has been prepared for wastewater treatment facilities for the Town of Pittsboro, and the proposed action is to construct a new wastewater treatment plant (WWTP) with a treatment capacity of 3.22 million - gallons per day (MGD) to satisfy the 20year planning horizon of the service area outlined in the EIS, including currently incorporated areas of the Town, areas in the Town's extraterritorial jurisdiction (ETJ), and areas beyond the ETJ that are under Chatham County's jurisdiction. This WWTP will maintain the Town's currently permitted 0.75 MGD discharge to Robeson Creek and the remaining 2.47 MGD will be discharged to the Haw River. The proposed design will achieve enhanced Biological Nutrient Removal inj a single sludge staged bioreactor. Major components in the WWTP will include a new influent pump station, preliminary treatment facilities, bioreactors, clarifiers, tertiary filters, a UV disinfection system, a 12-inch effluent discharge flume, and a biosolids handling facility. The new WWTP will be required to meet the nutrient limitations for discharges into the Jordan Lake watershed. Also, the WWTP will be capable of producing reuse quality effluent as measured for the effluent standards for five-day biochemical oxygen demand (BOD5), total suspended solids (TSS), and fecal coliform. The selected alternative and the anticipated environmental impacts are fully discussed in the EIS. Identified funding for this project consists of a public/private partnership that Pittsboro is exploring, as well as potential grant and loan funding sources; the Town will not secure Federal funding for any portion of the project outlined in the EIS. PURPOSE The purpose of this EIS for the new 3.22 MGD Robeson Creek WWTP is to satisfy SEPA requirements to address the direct, secondary, and cumulative impacts directly caused by construction of the proposed project or supported by growth within the WWTP's service area during the next 20 years. The EIS provides a detailed accounting of the likely impacts to the environment and cultural/historical resources for each of the treatment and effluent disposal alternatives, and contains mitigation strategies to address impacts resulting from the preferred treatment and disposal alternatives. ALTERNATIVES Several alternatives were identified during the planning process and the EIS provides a full discussion of those that were considered for a thorough evaluation. The preferred wastewater treatment alternative and the preferred effluent discharge alternative were independently determined to be the least environmentally damaging alternatives that met Pittsboro's 20 year planning horizon needs. Five alternatives were considered for wastewater treatment: 1. No Action. 2. Expansion of the existing Robeson Creek WWTP. 3. Construction of a new Robeson Creek WWTP. (This is the preferred treatment alternative.) 4. Connection to another publicly -owned WWTP. 5. Land application by spray irrigation. Pittsboro will maintain its existing discharge volume of 0.75 MGD to Robeson Creek with the new WWTP as long as the new facility can maintain effluent limitations outlined in the Roberson [sic] Creek TMDL. Two alternatives were considered for disposal of the remaining 2.47 MGD: 1. Haw River at the US-64 bridge. (This is the preferred second discharge alternative.) 2. Jordan Lake. Pittsboro has abided by a self-imposed building moratorium since April 2006 because its WWTP could not adequately manage high flows during wet weather events. A project funded under the American• Recovery and Reinvestment Ad of 2009 to construct flow equalization tanks at the head of the existing 0.75 MGD WWTP allowed the Town to allocate an additional 0.125 MGD wastewater treatment capacity. However, once this 0.125 MGD allocation is consumed Pittsboro will re -impose the moratorium until new treatment capacity is added under the project covered by the subject EIS. This project will allow improvement in the water quality of Robeson Creek and should not degrade the water quality of the Haw River. Also, the proposed project should not significantly negatively impact either the water quality or the water supply resource of Jordan Lake. ENVIRONMENTAL IMPACTS The EIS has been properly advertised and reviewed by State and Federal agencies. Extensive public input has been made into the planning process. Comments from agencies and citizens have been incorporated into the proposed project. All means of avoiding or minimizing environmental and cultural impacts outlined out in the EIS will be incorporated into the project. Moreover, the project will be designed and constructed to avoid adverse impacts to topography; soils; wetlands; land use; wetlands; prime or unique agricultural lands; public lands and scenic, recreational, and state natural areas; areas of archaeological or historical value; air quality; noise levels; water resources; forest resources; shellfish or fish and their habitats; and wildlife and natural vegetation. The project will require the following permitting activities: 1. Erosion and Sediment Control Plan. 2. NPDES Discharge Permit. 3. NPDES Stormwater Permit. 4. 404/401 Permitting. 5. Sewer line extension permitting. 6. Authorization to Construct. 7. North Carolina's Department of Transportation or owners of easements will be contacted for permission to cross property. 8. North Carolina's Board of Contractors will be contacted regarding installation of materials. 9. Department of Commerce -Utilities Commission -Gas Pipeline Safety Division will be contacted to ensure the project does not disturb its infrastructure. 10. North Carolina's Natural Heritage Program will be consulted to ensure that the project does not have significant impact on any rare, threatened or endangered species communities, habitats, etc., in the proposed project area. 11. Local planning and zoning may require special use permits. A copy of this Record of Decision will be sent to the Clearinghouse to be sent to all review agencies, and a notice of its availability will be published in the Environmental Bulletin.