NC0020354_Speculative Limits_20041123

NPDES DOCUHENT SCANNING COVER SHEET
NPDES Permit:
NC0020354
Pittsboro WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Technical Correction
A.
Instream Assessment (67b)
f
Speculative Limits
Environmental Assessment (EA)
Document Date:
November 23, 2004
This document is printed on reuse paper - ignore any
content on the resrerse side

TOWN OF
NANCY R. MAY
Mayor
DAVID B. HUGHES, P.E.
Town Manager
PAUL S. MESSICK, JR.
Town Attomey
P.O. Box 759 — 635 East Street
PITTSBORO. N.C. 27312
November 23, 2004
Ms. Coleen Sullins
Section Chief Division of Water Quality
N.C. Department of Environment and Natural Resources
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Re: Speculative Limits/ Potential Discharge to the Haw River
Ref. NPDES Permit NC0020354
Town of Pittsboro
Chatham County
Dear Ms. Sullins:
ram_
BOARD OF COMMISIONERS
//1 GENE BROOKS
MAX G. COTTEN
BURNICE N. GRIFFIN, JR.
CHRIS WALKER
CLINTON E. BRYAN, JR.
TELEPHONE
[phone]
FAX [phone]
ROWR
NOV 3 0 2004
DENR - WATER QUALITY
POINT SOURCE BRANCH
w
This letter is being sent to reiterate the Town of Pittsboro's desire and justification for a
future 4 MGD wastewater discharge as described in the Speculative Limit letter received
from David Goodrich dated September 14, 2004.
As different scenarios are discussed concerning nutrient allocation for the Haw River
wastewater dischargers, the Town believes it is imperative that significant consideration
be given to our present and future wastewater capacity concerns. As I have
communicated to you previously in a letter dated November 5, 2003, wastewater capacity
is one of the most pressing matters facing the Town. Between the recently imposed
TMDL for Roberson Creek and development interest and activity in Pittsboro and the
surrounding area, new discharge capacity is essential. The Town has been in discussions
with the Division of Water Quality seeking an alternative discharge location and
additional capacity for over 4 years. This is not an issue that has recently come up as a
response to the allocation scenarios. The following are some factors we would urge you
and the Division to consider:
CHARTERED 1787

As you may or may not know, the Town has in place a moratorium on new major
subdivision development. The reason for this moratorium is that currently approved
development at build out will for the most part use the remaining wastewater treatment
capacity.
The current area of the Extraterritorial Jurisdiction (ETJ) is approximately 26,393 acres.
The ETJ is considered the urban growth boundary and as such will likely be developed in
some form in the future. The current density of the incorporated town limits is
approximately 1.46 persons per acre which is fairly low density. If the ETJ is developed
at the same density it would equate to an additional 38,534 persons.
The development pattern in the surrounding area has tended toward small community
systems using traditional septic systems or relatively small package plants. A more
closely regulated, state of the art municipal system with biological nutrient removal
would seem to be preferable.
Pittsboro and Chatham County are in preliminary discussions concerning a shared
interest in a future wastewater system. These discussions could lead to a more
comprehensive regional approach to wastewater treatment for the area.
Considering the previously mentioned factors, the Town of Pittsboro feels that a 4 MGD
wastewater discharge is warranted and justified. We also feel that any allocation scenario
developed for the Haw River Arm should include this discharge rate.
If there are any questions concerning this Letter or any other related issue please contact
me. Thank you for your time and consideration.
Sincerely,e1/4-------
David B. Hughes, P.E.
Town Manager
Cc: David Goodrich
Michele Woolfolk
Sydney Miller

Michael F. Easley, Governor
State of North Carolina
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
September 14, 2004
Mr. David B. Hughes, P.E.
Town Manager
Town of Pittsboro
P.O. Box 759
Pittsboro, North Carolina 27312
Subject: Speculative Limits
Potential Discharge to Haw River
Ref. NPDES Permit NC0020354
Towns of Pittsboro
Chatham County
Dear Mr. Hughes:
This letter is in response to a request for speculative effluent limits for the potential
expansion and relocation of the Pittsboro wastewater treatment plant. Based on the meeting held
between the Town of Pittsboro and various state agencies July 14, 2004, it is the NPDES Units
understanding that Pittsboro will review all three locations described in Melba McGee's letter
dated May 27, 2004. This letter will provide Pittsboro with speculative limits for all three
locations. The Town will need to work with the various state and federal agencies, as well as
interested parties, to determine the best location for a point source discharge.
These speculative limits are based on our understanding of the proposal and of present
environmental conditions. The Division of Water Quality (DWQ) cannot guarantee that it will
issue the Town an NPDES permit to expand its discharge of treated wastewater into waters of the
State. Nor can we guarantee that the effluent limitations and other requirements included in any
permit will be exactly as presented here. Final decisions on these matters will be made only after
the Division evaluates a formal permit application for the discharge and notices the proposal for
public comment.
Environmental Assessments of New Projects and Expansions
Any entity proposing to construct new or expanded wastewater treatment facilities using
public funds or public (state) lands must first prepare an environmental assessment (EA) when
wastewater expansions equal or exceed 0.5 MGD. Please contact the Division's State
Environmental Policy Act (SEPA) coordinator, currently Alex Marks, at (919) 733 - 5083, ext. 555
for further information on EA requirements. DWQ will not accept a permit application for a
project requiring an environmental assessment until the Division has approved the EA and sent a
Finding of No Significant Impact (FONSI) to the state Clearinghouse for review and comment. Due
to the public interest in the area, the Town may also wish to investigate the possibility of
proceeding directly to an Environmental Impact Statement (EIS), in lieu of an EA. Again, the
Town may wish to contact Mr. Marks about this possibility (or Ms. Melba McGee, Environmental
Coordinator for DENR, 715-4194).
Engineering Alternatives Analysis (EAA)
In accordance with the North Carolina General Statutes, the most practicable wastewater
treatment and disposal alternative with the least adverse impact on the environment is required to
be implemented with any expansion. Therefore, a detailed engineering alternatives analysis (EAA)
must be prepared. The NPDES Unit requires the EAA as part of the Environmental Assessment or
Environmental Impact Statement The EAA must justify requested flows and provide an analysis of
potential wastewater treatment alternatives. Alternatives to a surface water discharge, such as a
spray/drip irrigation, wastewater reuse, or inflow/infiltration reduction, are considered to be
environmentally preferable.
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[phone]
FAX [phone]
On the Internet at http://h2o.enr.state.nc.us/

Mr. Hughes
Page 2
Permit applications for new or expanding flow will be returned as incomplete if all EAA
requirements are not adequately addressed. You may also wish to refer to the NPDES Unit
website for more information regarding requests for expansion,
http://h2o.enr.state.nc.us/NPDES/.
Speculative Effluent Limits
Based on the available information, tentative limits for the proposed discharge of 4 MGD flow to
the Haw River at three locations are outlined below. The three locations reviewed are: (1)
discharge to the Haw River upstream from the recently purchased tract of state property and
below 15-501; (2) discharge into the mainstem of Jordan Lake above Stinking Creek; (3)
discharge to the Haw River near US Highway 64. Also refer to Table 1 for an outline of the
speculative limits. Limits are the same for all three locations.
Flow Limits. The flow would be limited to 4 MGD at your request. This limit would be applied as
a monthly average.
BOD5 and NH3-N. The proposed limits for a 4 MGD discharge into this proximity of Jordan Lake
would be 5 mg/1 (BOD5) and 1.0 mg/1 (NH3-N) during the summer months, 10 mg/1 (BOD5) and
2.0 mg/1 (NH3-N) during the winter months.
Dissolved Oxygen. A minimum daily average dissolved oxygen level of 6 mg/1 must be maintained
in the effluent.
TSS. The limits for total suspended solids are standard for secondary treatment of municipal
wastewater (30 mg/1 monthly average).
Fecal Conform, pH. The limits for fecal conform bacteria and pH are derived to protect water
quality in the receiving stream and will likely remain the same as in the previous permit.
Chlorine. A total residual chlorine limit of 28 ug/1 (daily maximum) would be implemented in this
permit.
Chronic Toxicity Testing: For the discharge into the Haw River (proper) the 7Q l Os is estimated as
70 cfs. The toxicity testing requirement at 4 MGD will be Chronic Pass/Fail at 8.1% (this will be
applicable to location nos. 1 and 2). Should the Town of Pittsboro determine that discharge to
Lake Jordan is the most feasible option (location no. 3), the facility will be required to comply with
a 24 hour Acute Pass/Fail test using the fathead minnow species.
Toxicant Parameters: Estimation of toxicant parameters will not be given with this speculative
letter, but will be submitted as appropriate with the draft NPDES permit.
Nutrient Parameters: A nutrient model for Jordan Lake was recently developed. Meetings
between Division staff and the stakeholders for Jordan Lake are continuing to take place (with
specific allocations for each discharger not yet determined). We encourage the Town to become an
active participant in the Jordan Lake meetings. At this time, the Division of Water Quality can
provide only estimates of possible individual nutrient limits. For total nitrogen, Pittsboro would
likely receive a mass -based equivalent of 5 — 6 mg/1 TN. For total phosphorus, the Town would
likely receive a mass -based equivalent of 0.5 mg/1 TP.

Mr. Hughes
Page 3
As stated previously, these speculative limits are appropriate for a discharge of 4 MGD to
the three locations specified previously. If you have any additional questions about these limits,
feel free to contact Ms. Wilson at [phone], extension 510.
cc:
Sincerely,
David A. Goodrich, Supervisor
Point Source Branch
Surface Water Protection Section
Raleigh Regional Office/ WQS
Alex Marks, SEPA Coordinator, DWQ
Michelle Woolfolk, TMDL Unit
Melba McGee, Environmental Coordinator, DENR
Central Files
NPDES Unit Files
John Phillips, P.E. Diehl & Phillips, P.A.
219 East Chatham Street
Cary, NC 27511
US Fish and Wildlife Service, Ecological Services
Attn: Sara Myers
P.O. Box 33726
Raleigh, NC 27636-3726
NC WRC, Inland Fisheries Attn: Shari Bryant
1721 Mail Service Center
Raleigh, NC 27699-1721
Carmen Boyette US ACOE
Jordan Lake
2080 Jordan Dam Road
Moncure, NC 27559

Mr. Hughes
Page 4
Table 1
Speculative Limits for the Town of Pittsboro (for flow of 4 MGD)
Scenarios
Site Description
Proposed
Flow (MGD)
BOD5 mg/1
(sum/win)
NH3-N mg/1
(sum/win)
D.O.
mg/1
Instream
waste
concentration
(IWC %)
1
Haw River
upstream from
recently purchased
tract and below 15-
501
4.0
5.0
/
10
1.0
/
2.0
6.0
Chronic P/F at
8.1%
2
Mainstem of
Jordan Lake above
Stinking Creek
4.0
5.0
/
10
1.0
/
2.0
6.0
_
24 hr Acute
P/F
3
Haw River near
Highway 64
4.0
5.0
/
10
1.0
/
2.0
6.0
Chronic P/F at
8.1%
Stream flows:
Haw River (Location Nos. 1 and 3), Class WS IV, NSW
DA = 1200 mi2
7Q10s = 70 cfs
7Q 10w = 140 cfs
Jordan Lake (Location No. 2), WS-IV, B, NSW, CA
7Q10s = indeterminate due to lake conditions
2

Re: pitts spec
4
Subject: Re: pitts spec
From: Alex Marks <[e-mail]>
Date: Mon, 13 Sep 2004 11:28:25 -0400
To: Susan Wilson <[e-mail]>
Susan - Looks good to me.
For inland fisheries we should also send one to Shari Bryant - email would work - Shari Bryant
<bryants5Rearthlink.net>. she will likely be the main reviewer for them.
For FWS - use Peter Benjamin, Ecological Supervisor - same address.
For army corps - MS. Carmen Boyette ([e-mail])
Jordan Lake
2080 Jordan Dam Road
Moncure, NC 27559
Thanks
Susan Wilson wrote:
check the contact names/addresses for the resource agencies while you're looking at it, if
you would.
1 of 1
9/13/2004 3:39 PM

Facility: Pittsboro WWTP
Discharge to: Haw River
Residual Chlorine
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (UG/L)
UPS BACKGROUND LEVEL (UG/L)
IWC (%)
Allowable Conc. (ugll)
Fecal Limit
Ratio of 11.3 :1
70
4
6.2
17.0
0
8.14
208.94
DA = 1200 mi2
7010s = 70 cfs
7Q 10w = 140 cfs
Ammonia as NH3
(summer)
7010 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
UPS BACKGROUND LEVEL (MG/L)
IWC (%)
Allowable Concentration (mg/I)
Ammonia as NH3
(winter)
7Q10 (CFS)
200/100mI DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (MG/L)
UPS BACKGROUND LEVEL (MG/L)
IWC (%)
Allowable Concentration (mg/l)
For Minor domestic -type facilities:
Minimum of 2 mg/I (summer) NH3-N; 4 mg/I (winter) NH3-N
Chlorine:
Residual chlorine must be capped at 28 ug/I to protect for acute toxicity effects
70
4
6.2
1.0
0.22
8.14
9.81
140
4
6.2
1.8
0.22
4.24
37.48

Re: Pittsboro
Subject: Re: Pittsboro
From: Mike Templeton <[e-mail]>
Date: Wed, 11 Aug 2004 17:25:35 -0400
To: Susan Wilson <susan.a.wilson©ncmail.net>
The outcome of the nutrient allocation work in the Haw River basin remains to be seen, but
I can give you a rough idea of what Pittsboro and others might expect. The scenarios we've
considered so far would give the large dischargers a set of allocations equivalent to 5-6
mg/L TN and approx. 0.5 mg/L TP. There is still some question as to whether Pittsboro
should be considered a large or a small discharger; given their request for an expansion to
4 MGD, I would group them with the big boys.
( i4 )
Susan Wilson wrote:
Mike -
When you get a chance (ha!ha!) could you send me the data for Pittsboro so I'll be able to
give them some idea of the potential nutrient limits they would get? i did pass word
along to their consultant that Pittsboro needs to go to those Jordan Lake meetings and
fight for their allocation (based on 20 year projected flow - told him that was my opinion
and that would be what i would do if i were in their shoes). thanks!
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ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor
MEMORANDUM
William G. Ross Jr., Secretary
TO: Chrys Baggett
State Clearinghouse
FROM: Melba McGee 01—'
Environmental Coordinator
RE: 04-0275 Scoping, Proposed NPDES Permit for the Town of Pittsboro
DATE: May 27, 2004
The Department of Environmental and Natural Resources (DENR) has reviewed the
Town of Pittsboro's request for input regarding the referenced proposal. The Department
appreciates the Town's willingness to pursue other alternatives based on the concerns
expressed by our resource agencies during our earlier scoping review. Scoping is the first
opportunity for participants on both sides of a project to identify concerns and possible
alternatives. It is my understanding that there has been some communication with the
Division of Water Quality and through these discussions a number of other different
alternatives were identified for the NPDES discharge location. From the Division of
Water Quality's perspective the riverine portion of the Haw River appeared to be the
most feasible alternative for a discharge; however, other DENR agencies not involved in
the earlier discussions have raised issues with this location. In particular, issues have
been raised with water quality ratings, state and federal endangered species, recently
purchased state property and other aquatic species.
Our resource agencies have identified and laid the groundwork of some potential
alternatives. Any number of the recommended alternatives will raise it's own particular
issues and the project as a whole will raise the question of secondary and cumulative
impacts. Based on my discussions with DENR agencies the following options seemed to
be the most feasible: (1) Discharge upstream from the recently purchased tract of state
property and below 15-501; (2) Discharge into mainstem of Jordan Lake above Stinking
Creek; or (3) Discharge along US 64 in DOT's easement.
1601 Mail Service Center, Raleigh, North Carolina 27699-1601
Phone: [phone] FAX: [phone] Internet: www.enr.state.nc.us/ENR
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 1 10% Post Consumer Paper

Our primary interest at this time is to continue to communicate and develop a solution
that has the least significant environmental impacts. It is the Department's
recommendation that the Town of Pittsboro meet with DENR agencies in the next few
weeks so a clearer resolution of issues can be reached. The Division of Water Quality
has been identified as the lead agency. This meeting can be coordinated through
contacting Alex Marks at 733-5083 ext. 555 or myself at 715-4194. I would also suggest
that the US Fish and Wildlife Service and the Corps of Engineers attend. This will be
key in bring the various state and federal issues to the surface and everyone making a
combine effort to help Pittsboro locate a feasible discharge location. We will also need to
discuss whether an Environmental Assessment or an Environmental Impact Statement is
appropriate. This decision will be based not only on the environmental issues but also
will need to consider public input.
Thank you for the opportunity to respond.
Attachments
_ cc: Alex Marks

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek. P. E. Director
Division of Water Quality
-� Coleen H. Sullins, Deputy Director
Division of Water Quality
May 10, 2004
MEMORANDUM
TO: Melba McGee, Department of Environment and Natural Resources
FROM: Alex Marks, Division of Water Quality, Water Quality Section #1,`"---
SUBJECT: Scoping for Pittsboro WWTP Expansion (#04-0275)
The Water Quality Section (Section) in the Division of Water Quality has reviewed the subject
scoping document for the Town of Pittsboro's proposed wastewater treatment plant expansion
project. A previous scoping document for the project was reviewed and commented on by the
Section in January 2003; however, at that time Pittsboro had yet to decide upon the exact location
for the treatment plant's discharge.
As we previously stated, the Section will serve as the project's lead coordinating agency for
preparation and review of the necessary State Environmental Policy Act (SEPA) document. We
recommend that the Town re -review our 2003 memorandum (attached) detailing the various
materials to be included in the environmental document.
Additional guidance regarding SEPA document preparation for Section projects can be found at
http://h2o.enr.state.nc.us/sepa/index.htm. The applicant may contact me at 919.733.5083 x555.
CC: NPDES Permitting Unit
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone]
vo
cDENR
Customer Service
1477-623-6748

DIVISION OF WATER QUALITY
NPDES Unit
May 10, 2004
MEMORANDUM
TO: Curtis Weaver
FROM: Susan A. Wilson
SUBJECT: Request for stream flows
Attached is a request form and map for natural stream flows for the
Haw River in the Cape Fear River Basin. The requested site is
approximately 1 mile upstream from Hwy. 64 along the Haw River (and
below 15/501).
The needed information is the drainage area, average flow, summer
and winter 7Q10 flows, and the 30Q2 flow.
Please provide this information at your earliest convenience. I can
be contacted at 919-733-5083 ext 510 if there are any questions. Thank you
very much for your assistance.

•
Date_5/10/2004
Requested by
USGS Flow Data Request
Susan A. Wilson
DENR/DWQ/NPDES Unit
919 —733-5083 ext. 510
Site No. 1 County Chatham River Basin _Cape Fear
NRCD Sub Basin _030604_ Map No. or Name _ E22NE/ Merry Oaks Quad_
Station No. Secondary or Primary Rd
Stream Name Haw River
Data Requested: Drainage Area X Average Flow _X
Summer 7Q10 _ X_ Winter 7Q10 X 30Q2 _X
Site appx. 1 mile upstream of Hwy 64
Site No. 2 County River Basin
NRCD Sub Basin Map No. or Name
Station No. Secondary or Primary Rd
Stream Name
Data Requested: Drainage Area Average Flow
Summer 7Q10 Winter 7Q10 30Q2
Site No. 3 County River Basin
NRCD Sub Basin Map No. or Name
Station No. Secondary or Primary Rd
Stream Name
Data Requested: Drainage Area Average Flow
Summer 7Q10 Winter 7Q10 30Q2

Division of Parks and Recreation
MEMORANDUM
TO: Melba McGee, DENR Environmental Coordinator
FROM: Brian Strong, DPR Environmental Review Coordinator
DATE: May 7, 2004
SUBJECT: Scoping Assistance for Proposed NPDES Permit: Town of Pittsboro
Project No. 04-0275
The North Carolina Division of Parks and Recreation (DPR) appreciates the opportunity
to comment on the scoping request for the proposed NPDES permit for the Town of Pittsboro.
The Division has three concerns with the proposed project as it appears in the scoping letter:
1) Current ownership of the tract proposed for the outfall structure; 2) Impacts to rare and
endangered species located near the proposed outfall structure; and 3) Secondary and
commutative impacts associated with the proposed project.
Ownership of the Tract for the Proposed OutfalI Structure
The current proposed location for the outfall is sited on a recently purchased tract of state
property managed by the North Carolina Division of State Parks. This parcel was purchased to
protect the Haw River from encroachment pressures and to protect the unique slopes and rare
species in and around the Haw River. The Haw River Slopes area was purchased for use as
compensatory mitigation by the Ecosystem Enhancement Program (EEP). Protection of the site
must be in accordance with the Federal Guidance for Establishment, Use and Operation of
Mitigation Bank, 60 Fed. Reg. 58605. Native woody vegetation on preservation sites purchased
by EEP is protected from cutting in perpetuity. Attached is a copy of the deed including the
conservation easement requirement. .
The Ecosystem Enhancement Program has stated that they cannot support the use of the
Haw River Levees and Slopes tract by the City of Pittsboro as a sewer line. Such a disturbance
would compromise the integrity of the natural area and segment the 300' buffer area. Edge
effects would reduce the ecological effectiveness of the corridor, and digging the pipeline would
encourage the spread of invasive exotic vegetation throughout the floodplain.
Impacts to Rare Threatened and Endangered Species
There are records for the federal and state endangered Cape Fear shiner (Notropis
mekistocholas); federal species of concern and state endangered brook floater (Alasmidonta
varicosa) and yellow lampmtissel (Lampsilis cariosa); and the federal species of concern and
state significantly rare Septima's clubtail (Gomphus septima) in the Haw River above B.E.
Jordan Reservoir. Additionally, B.E. Jordan Reservoir supports a diverse fishery including

largemouth bass (Micropterus salmoides), crappie (Pomoxis sp.), sunfish (Lepomis sp.), catfish
(Ictalurus sp.) and striped bass (Morone saxatilus).
The Town previously investigated a potential discharge into the lower Rocky River or the
Deep River near its confluence with the Rocky River. This system supports the federal and state
endangered Cape Fear shiner (Notropis mekistocholas) and several other rare and sensitive
species. In addition, the location of the proposed discharge was within U.S. Fish and Wildlife
Service (USFWS) designated critical habitat for the Cape Fear shiner.
Secondary and Commutative Impacts Associated with the Proposed Project
The Division is concerned about the direct impacts from the project and the secondary
and cumulative impacts from development facilitated by the expansion. The project will
facilitate an increase in industrial, commercial; and residential development within the service
area. Increases in impervious surfaces can result in stream degradation without the
implementation of appropriate stormwater quantity and quality control measures. Additionally,
the pollutants (e.g., sediment, heavy metals, herbicides, pesticides, and fertilizers) washed from
roads and urban landscapes can adversely affect and extirpate species downstream of developed
areas. Additional impervious surface associated with residential, commercial, and industrial
development and highway infrastructure results in increase stormwater runoff that can exert
significant impacts on stream morphology. This will cause further degradation of aquatic
habitats through accelerated stream bank erosion, channel changes, bedload changes, altered
substrates, and scouring of the stream channel. Secondary development that follows
infrastructure projects causes the loss, degradation, and fragmentation of terrestrial habitats as
well.
The project has the potential to result in significant direct, secondary, and cumulative
impacts; therefore, we recommend that the applicant consider implementation of strong
mitigation efforts. If an acceptable mitigation plan that will reduce impacts to a level below the
threshold of significance cannot be agreed upon, we recommend that an Environmental Impact
Statement be developed. The Division recommends adopting the proposed mitigation measures
suggested by the North Carolina Wildlife Resources Commission.
Recommendations
Based on the potential impacts of the proposed site discussed in the April 19, 2004
scoping letter, the Division recommends that other potential locations be evaluated. The
Division recommends the following alternatives: 1) A discharge to the Haw River arm of B.E.
Jordan Reservoir downstream of the confluence with Robeson Creek; 2) A discharge location to
Haw River above B.E. Jordan Reservoir, preferably with the outfall located at U.S. Highway 64;
3) A discharge to Haw River below B.E. Jordan Reservoir dam; and 4) a discharge to the Cape
Fear River below Buckhom dam. Land application, wastewater reuse and water conservation
should be included as an integral component of each alternative. If you have any questions
regarding these comments please contact me at 919) 715-8711.

...sr...
Chatham County 1212-19-2003
NORTH CAROLINA
Real Fatale
Excise Tax 55 Q9o.00
Tax Lot No
Verified by
by
BOOK 107 6 MOE 109
FILED
CHATHAM COUNTY
REBA G. THOMAS
REGISTER OF DEEDS
FILED Dec 19, 2003
AT 09:14:41 am
BOOK 01076
START PAGE 0109
END PAGE 0111
INSTRUMENT # 20217
NORTH CAROLINA SPECIAL WARRANTY DEED
Excise Tax: $5,090.00
i
Recording Time, Book and Page
Parcel Identifier No.
County on the day of . 20 . .
Mail after recording to State Property Office, 1321 Mail Service Center, Raleigh, NC 27699-1321
This instrument was prepared by Jeffrey H. Potter, 402 Oregon Street, Durham, North Carolina
Brief description for the Index
THIS DEED made this day of December
, 2003 , by and between
GRANTOR
DUKE UNIVERSITY, a North Carolina nonprofit corporation
402 Oregon Street
Duke University
Durham, North Carolina 27705
GRANTEE
THE STATE OF NORTH CAROLINA
c/o State Property Office
1321 Mail Service Center
Raleigh, North Carolina 27699-1321
Enter in appropriate block for each party: name, address, and, if appropriate, character of entity, e.g. corporation or partnership.
The designation Grantor and Grantee as used herein shall include said parties, their heirs, successors, and assigns, and shall include
singular plural, masculine, feminine or neuter as required by context.
WITNESSETH, that the Grantor, fora valuable consideration paid by the Grantee, the receipt of.which is hereby acknowledged, has and
by these presents does grant, bargain, sell and convey unto the Grantee in fee simple, all that certain lot or parcel of land situated in the
City of , New Hope ... Township, Chatham County, North Carolina and more
particularly described as follows:
See Exhibit "A" attached hereto and incorporated herein.

BOOK 10 "f S PAGE 110
jteproperty hereinabove described was acquired by Grantor by instrument recorded in Deed Book 320, Page 403
d'
A map showing the above described property is recorded in Plat Book. 2003 Pages.... 138 and 412-415
And the Grantor covenants with the Grantee, that Grantor of allhas
such
r throughGGrantor excep crantor for the except ors
, and Grantor will
warrant and defend the title against the lawful claims persons claim rig by, under or
hereinafter stated.
Title to the property hereinabove described is subject to the following exception:
1. The above described property is subject to any recorded or unrecorded right-of-way in favor of U.S. Highway 64 and
the North Carolina Department of Transportation.
2. The above described property is subject to any easements which might now exist in favor of any Public Utility
Company.
3. The above described property is subject to the rights of others in and to use and flow of Haw River.
4. The above described property is subject to any matters which a recent and accurate survey might disclose.
•
IN WITNESS WHEREOF, the Grantor has hereunto set his hand and seal, or if corporate,tr as caused
uits dBhiars s inotrumeDirect to
otbe
be
signed in its corporate name by its duly authorized officers and its seal to be hereunto affixed by h'
day and year first above written.
By:
DUKE UNIVERSITY
Corporate Nlrre)
Ic
I
✓� - (SEAL)
ecutive Vice President
(SEAL)
SEAL -STAMP
(SEAL)
(SEAL)
NORTH CAROLINA, County.
I, a Notary Public of the County and State aforesaid, certify that
Grantor
personally appeared before me this day and acknowledged the execution of the foregoing instrument. W itnes!
my hand and official stamp or seal, this day of , 20
c.Pi
f.= .: DIAR
o _ - s being authorized to do so, executed the foregoing deed on behalf of the corporation.
My commission expires:
•
NORTH CAROLINA,
. :f ; a Notary Public of the County and State aforesaid, certify that Tallman Tres
•..:Ie
��►L�isonally came before me this day and acknowledged that _he is
:•P c
_ �,: c t -zDuke University a North Carolina nonprofit corporation, and that _he as
j� �,•,
Durham
County.
Notary Publi=
11
Executive Vice President c
Executive Vice Presiden
'.'' ; c •.,...ri•`— L :*' this _ day of December 20 .
• t •'�J�i� t �QV� ��� Witness my hand and official stamp or
rs
I M nQ Q .P6----Notary Pub
Mycommission expires: 12•l �Q la��
t•
r in/ itdirt ‘�'
The foregoing Certificate(s) of
is/are certified to be correct This instrument and this certificate are duly registered at the date and time and in the Book and Page sho
on the first page hereof.
By
REGISTER OF DEEDS FOR
Deputy/Assistant-Register of Deeds.
COUN1

BOOK 107 O PAGE 111
EXHIBIT "A"
TRACT ONE: BEING all those three tracts containing 56.737 Acres (Tract 20),
169.553 Acres (Tract 13) and 99.443 Acres (Tract 12), respectively as shown on a Plat entitled,
"DUKE UNIVERSITY, PORTION OF DUKE FOREST, CHATHAM COUNTY", dated
4/24/2003, prepared by Triangle Surveyors, and recorded in Plat Slide 2003-138, Chatham
County Registry, to which Plat reference is hereby made for greater certainty of description.
TRACT TWO: BEING all that certain 320.261 Acres, more or less, as described on a
Plat entitled, "Plat of Survey of "HAW SLOPES STATE NATURAL AREA" for North Carolina
Division of Parks & Recreation", dated November 14, 2003, prepared by Berkley -Howell &
Assoc., P.C. and recorded in Plat Slide 2003-413, Chatham County Registry, to which Plat
reference is hereby made for greater certainty of description. For surveyor notes and
certifications, refer to Plat Slide 2003-412.
TRACT THREE: BEING all that certain 447.219 Ac., more or less, as described on a
Plat entitled, "Plat of Survey of "HAW SLOPES STATE NATURAL AREA" for North Carolina
Division of Parks & Recreation", dated November 14, 2003, prepared by Berkley -Howell &
Assoc., P.C., and recorded in Plat Slide 2003-414, Chatham County Registry, to which Plat
reference is hereby made for greater certainty of description. For surveyor notes and
certifications, refer to Plat Slide 2003-412.
TRACT FOUR: BEING all that certain 123.876 Ac., more or less, as described on a Plat
entitled, "Plat of Survey of "HAW SLOPES STATE NATURAL AREA" for North Carolina
Division of Parks & Recreation", dated November 14, 2003, prepared by Berkley -Howell &
Assoc., P.C., and recorded in Plat Slide 2003-415, Chatham County Registry, to which Plat
reference is hereby made for greater certainty of description. For surveyor notes and
certifications, refer to Plat Slide 2003-412.
TRACT FIVE: ALL the right, title, interest and estate of said party of the first part in and
to the waters and bed of Haw River and in and to all rocks and islands in said River.
TRACT SIX: Any and all other real estate not described hereinabove conveyed which
was conveyed to Duke University by Duke Power Company by deed dated December 28, 1966
and recorded in Deed Book 320, Page 403, Chatham County Registry.
CONSERVATION EASEMENT: The State of North Carolina has received payment
from the Ecosystem Enhancement Program for acquisition of the above described property in
consideration of which the State of North Carolina has agreed to the establishment of a perpetual
riparian buffer extending 300' from the top banks of the Haw River. This 300' will forever be
conserved and managed in a manner that will protect the quality of the waters of the Haw River
and otherwise promote the public purposes authorized under the provisions of N.C. Gen. Stat.
§ 143-214.8 et seq.
This paragraph creates neither rights nor responsibilities on the part of the Grantor, its
heirs and/or assigns.
Chatham County, North Carolina
REBA G. THOMAS Register of Deeds
The foregoing certificate(s) of
. LYNNETTE G PUNNELL
notary/notaries public
As/are certi to be correct.
(44A-i

Lower Haw River
State Natural Area
irtly•-;*:,A1114--- 6h" ..storiN
maw
• tigi""
kg "44v"
a
1,"A341
=I State Natural Area
State Recreation Area
, Wildlife Resources Commision
0
2000
4000 Feet
April 2004

North Carolina Wildlife Resources Commission
Charles R. Fullwood, Executive Director
MEMORANDUM
TO: Melba McGee, Environmental Coordinator
Office of Legislative and Intergovernmental Affairs
FROM: Shari L. Bryant, Piedmont Region Coordinator
Habitat Conservation Program
DATE: 6 May 2004
SUBJECT: Request for Environmental Document Scoping Assistance for a Proposed NPDES Permit,
Town of Pittsboro, Chatham County, North Carolina, DENR Project No. 04-0275.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
subject document and we are familiar with the habitat values of the area. Our comments are provided in
accordance with provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16
U.S.C. 661 et seq.), the North Carolina Environmental Policy Act (G.S. 113A-1 through 113A-10; 1
NCAC 25), North Carolina General Statutes (G.S. 113-131 et seq.), and the North Carolina Administrative
Code l 5A NCAC 101.0102.
The Town of Pittsboro is evaluating alternatives for an increase in its wastewater treatment and
disposal capabilities. The Town presently discharges to Robeson Creek, a tributary of the Haw River in
the Cape Fear River basin. Due to effluent limitations in Robeson Creek, the Town is investigating
potential discharge into the Haw River above B.E. Jordan Reservoir. Proposed discharge volume is 4.0-
6.0 million gallons per day.
There are records for the federal and state endangered Cape Fear shiner (Notropis mekistocholas);
federal species of concern and state endangered brook floater (Alasmidonta varicosa) and yellow
lampmussel (Lampsilis cariosa); and the federal species of concern and state significantly rare Septima's
clubtail (Gomphus septima) in the Haw River above B.E. Jordan Reservoir. Additionally, B.E. Jordan
Reservoir supports a diverse fishery including largemouth bass (Micropterus salmoides), crappie (Pomoxis
sp.), sunfish (Lepomis sp.), catfish (Ictalurus sp.) and striped bass (Morone saxatilus).
The Town previously investigated a potential discharge into the lower Rocky River or the Deep
River near its confluence with the Rocky River. This system supports the federal and state endangered
Cape Fear shiner (1Votropis mekistocholas) and several other rare and sensitive species. In addition, the
location of the proposed discharge was within U.S. Fish and Wildlife Service (USFWS) designated critical
habitat for the Cape Fear shiner. We strongly recommended that the applicant evaluate other potential
discharge sites that would not impact the Cape Fear shiner and its habitat (Pender, 13 January 2003). In
the Preliminary Engineering Report (October 2003), the applicant stated that several alternatives had been
E•el
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] ext. 281 • Fax: [phone]
IIS.17-6frt,-SEE queRJH '1•S
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6 May 2004
Town of Pittsboro NPDES Scoping
Project No. 04.0275
investigated including Rocky River, Deep River, and Haw River (east of town and below B.E. Jordan
Reservoir dam) and the proposed location for the second discharge appeared to be the Haw River below
B.E. Jordan Reservoir dam.
A discharge to Haw River above B.E. Jordan Reservoir has the potential impacts to Cape Fear
shiners and its habitats. Another alternative for the Town to consider would be to discharge to the Haw
River arm of B.E. Jordan Reservoir downstream of the confluence with Robeson Creek. However, a
discharge at this location would involve a utility easement across U.S. Army Corps of Engineers property
and NCWRC game lands. Generally the NCWRC does not support utility easements on game lands when
other feasible alternatives exist.
We have concerns about impacts to fisheries, aquatic and wildlife resources with any of the
alternatives that have been proposed. We recommend that in addition to evaluating a discharge location to
Haw River above B.E. Jordan Reservoir, preferably with the outfall located at U.S. Highway 64, that the
applicant thoroughly consider and evaluate each of these other alternatives: 1) a discharge to the Haw River
arm of B.E. Jordan Reservoir downstream of the confluence with Robeson Creek; 2) a discharge to Haw
River below B.E. Jordan Reservoir dam; and 3) a discharge to Cape Fear River below Buckhorn dam.
Land application, wastewater reuse and water conservation should be included as an integral component of
each alternative.
Regardless of the discharge location, we are concerned about the direct impacts from the project
and the secondary and cumulative impacts from development facilitated by the expansion. The project will
facilitate an increase in industrial, commercial, and residential development within the service area.
Increases in impervious surfaces can result in stream degradation without the implementation of
appropriate stormwater quantity and quality control measures. Additionally, the pollutants (e.g., sediment,
heavy metals, herbicides, pesticides, and fertilizers) washed from roads and urban landscapes can adversely
affect and extirpate species downstream of developed areas. Additional impervious surface associated with
residential, commercial, and industrial development and highway infrastructure results in increase
stormwater runoff that can exert significant impacts on stream morphology. This will cause further
degradation of aquatic habitats through accelerated stream bank erosion, channel changes, bedload
changes, altered substrates, and scouring of the stream channel. Secondary development that follows
infrastructure projects causes the loss, degradation, and fragmentation of terrestrial habitats as well.
The project has the potential to result in significant direct, secondary,. and cumulative impacts;
therefore, we recommend that the applicant consider implementation of strong mitigation efforts. If an
acceptable mitigation plan that will reduce impacts to a level below the threshold of significance cannot be
agreed upon, we recommend that an Environmental Impact Statement be developed. We offer the
following recommendations to help address secondary and cumulative impacts associated with this project
and to reduce impacts to fish and wildlife resources.
1. We recommend the maintenance or establishment of a minimum 100-foot native forested buffer along
each side of perennial streams and 50-foot native forested buffer along each side of intermittent streams
and wetlands throughout the present and future service areas or the entire municipal jurisdiction (EPA
2000; Stewart et al. 2000). We additionally encourage the implementation of buffers on ephemeral
streams due to the important functions that they provide as headwater streams (Alexander et al. 2000;
Peterson et al. 2001). Buffers should be measured horizontally from the edge of the stream bank
(Knutson and Naef 1997), which may result in wider buffers on higher gradients, and must be provided
over the entire length of stream, including headwater streams. Further, we recontinend leaving 30% of
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Page 3
6 May 2004
Town of Pittsboro NPDES Scoping
Project No. 04-0275
the development area as greenspace, which would include buffers and wetlands and ensure that the
greenspace is connected to natural resources.
Wide, contiguous riparian buffers have greater and more flexible potential than other options to
maintain biological integrity (Horner et al. 1999) and could ameliorate many ecological issues related
to land use and environmental quality (Naiman et al. 1993). As expansion of developed areas
continues into the watershed, wildlife habitat can change, become fragmented, and even disappear.
Riparian buffers provide travel corridors and habitat areas for wildlife displaced by development. In
addition, riparian buffers serve to protect water quality by stabilizing stream banks, filtering capacity
of stormwater runoff, and provide habitat for aquatic and fisheries resources.
2. We recommend that delineation of streams be conducted for the municipal service area according to U.
S. Anny Corps of Engineers (USACOE) or N. C. Division of Water Quality (NCDWQ) methodology.
This information can be found at http://h2o.enr.state.nc.us/ncwetlands/strmfrm.html (accessed May
2004). U. S. Geological Survey (USGS) maps underestimate the extent of streams. Recent research
has shown that USGS maps. can underestimate total stream length in the Piedmont of North Carolina
by 25 % (Gregory et al. in press).
3. We recommend that fewer lines, water lines, and other utility infrastructure be kept out of riparian
buffer areas (Knutson and Naef 1997; and references therein). All utility crossings should be kept to a
minimum, which includes careful routing design and the combination of utility crossings into the same
right-of-way (provided there is not a safety issue). Discontiguous buffer segments can impair riparian
functions disproportionate to the relative occurrence of the breaks in the buffer (May and Horner 2000;
Van Sickle 2000), and multiple crossings can result in cumulative impacts. The directional bore
(installation of utilities beneath the riverbed, avoiding impacts to the stream and buffer) stream
crossing method should be used for utility crossings wherever practicable, and the open cut stream
crossing method should only be used when water level is low and stream flow is minimal. Manholes or
similar access structures should not be allowed within buffer areas. Stream crossings should be near
perpendicular (75° to 105°) to stream flow and should be monitored at least every three months for
maintenance needs during the first 24 months of the project and then annually thereafter. Sewer lines
associated with crossing areas should be maintained and operated at all times to prevent the discharge
to land or surface waters. We recommend a minimum 50-100 feet setback on all streams, lakes, and
wetlands for these structures, which falls in line with the recommended buffer widths. In
circumstances where minimum setbacks cannot be attained, sewer lines shall be constructed of ductile
iron or other substance of equal durability. Further, pesticides (including insecticides and herbicides)
should not be used for maintenance of rights -of -way within 100 feet of perennial streams and 50 feet of
intermittent streams, or within floodplains and wetlands associated with these streams.
4. Avoid the removal of large trees at the edges of construction corridors. Re -seed disturbed areas with
seed mixtures that are beneficial to wildlife. Avoid fescue based mixtures because fescue is invasive
and provides little benefit to wildlife. Native, annual small grains appropriate for the season are
preferred and recommended (See http://www.csb.cnr.statc.nc.us/wctplant/wctland plants.htm; accessed
May 2004). Where feasible, use woody debris and logs from corridor clearing to establish brush piles
and downed logs adjacent to the cleared right-of-way to improve habitat for wildlife. Allowing the
corridor area to revegetate into a brush/scrub habitat would maximize benefits to wildlife. For areas
adjacent to residential areas, a native shrub/grass option may also be beneficial. Minimize corridor
maintenance and prohibit mowing between April 1 and October 1 to m impacts to nesting
wildlife. We suggest a maintenance schedule that incorporates only a portion of the area —one third of
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Page 4
6 May 2004
Town of Pittsboro NPDES Soaping
Project No. 04-0275
the area, for example —each year instead of the entire project every 3 or 4 years. Herbicides and
pesticides should never be used in wetland areas or near streams, as described above in item 3.
5. We recommend that the local governments prohibit commercial or residential development within the
100-year floodplain. Undeveloped floodplains strongly influence aquatic systems, support a
combination of riparian and upland vegetation used by aquatic and terrestrial wildlife, supply a rich
source of food to aquatic communities (Junk et al. 1989), and provide an important sediment trapping
function (Palik et al. 2000). The filling of floodplains increases the potential for flooding of adjacent
properties and interferes with the natural hydrologic process of the waterways. It also disrupts the
continuity of migration corridors for wildlife. Instead, we recommend that developers set aside a
portion of the land to be developed as green space and concentrate these areas along the streams and
rivers (see Item 1 above). In addition we encourage "infill" (new development in unused or
underutilized land in existing urban areas) development in urbanized portions of the jurisdiction and
recommend the site practices for infill and brownfield development issued by the U. S. Environmental
Protection Agency (EPA) (http://www.cpa.gov; accessed May 2004) and the Center for Watershed
Protection (http://wv,-w.cwp.org/; accessed May 2004). Floodplain maps may need to be updated to
reflect development of the watershed. Floodplain remapping studies in Charlotte showed that buildout
conditions would result in a floodplain width change from an average of 429 feet to 611 feet
(httviAvww.charmedk.ora/DepartmentsfLUESA/Water+and+Land+Resources/Proerams/Floodplains/
Flood+Maps.htm; accessed May 2004).
6. We recommend that the local government limit impervious surfaces to less than 10% of the watershed
(Schueler 1994; Arnold and Gibbons 1996; Doll et al. 2000; Mallin et al. 2000; May and Horner 2000;
Stewart et al. 2000; Paul and Meyer 2001). The construction of roadways and other impervious
surfaces in new neighborhoods can produce short-term direct impacts as well as long-term cumulative
effects. Multiple studies have shown that stream degradation occurs at approximately 10% coverage
by impervious surfaces (Schueler 1994; Arnold and Gibbons 1996; Doll et al. 2000; Marlin et al.
2000; May and Homer 2000; Stewart et al. 2000; Paul and Meyer 2001). Likewise, the Wake County
Watershed Management Plan Task Force performed a correlation analysis of impervious surfaces to
watershed classification based on water quality data, and they found that watersheds of unimpaired
streams averaged 8% imperviousness, impacted streams averaged 11%, and degraded streams averaged
24%(http://projccts.ch2m.com/WakeCounty/: accessed May 2004).
We also recommend that the local government provide for sufficient open. space to effectively reduce
impervious surface so that predevelopment hydrographic conditions are maintained, limit curb and
gutter in new developments, and prevent direct discharges of stormwater into streams. To achieve no
net change in the hydrology of the watershed, we recommend installation of grassed swales in place of
curb and gutter and on -site stormwater management (i.e. bioretention areas or other attenuation
measures). These designs often cost less to install (Kwon 2000) and significantly reduce environmental
impacts from residential development. Information regarding financing stormwater management can be
found at http://stormwaterfinance.urbancenter.iupui.edu/ (accessed May 2004).
Many of these recommendations have been applied in Maryland to protect the Chesapeake Bay from
water quality degradation (MDE 2000). Suggested examples to accomplish the <10% impervious goal
are using conventional designs at a level of <10% imperviousness or using conservation clusters with
higher densities, with dedicated open space and other stormwater control measures to mimic the
hydrograph consistent with an impervious coverage of less than 10%. Reduction of road widths is one
method to reduce overall impervious surface coverage. The N. C. Department of Transportation
(NCDOT) has issued road guidelines that allow for the reduction in street widths when compared to
9 •d t TSt►-6t►t,-9CC
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Page 5
6 May 2004
Town of Pittsboro NPDES Scoping
Project No. 04-0275
standard secondary road guidelines. This material can be found at
http://www.doh.dot.state.nc.us/operations/tnd.pdf (accessed May 2004). In addition, there are site
planning practices that, when incorporated with the above mentioned road building guideline, can
further reduce the amount of impervious surface within a site (see recommendations in the document
Better Site Design (Center for Watershed Protection; http://www.cwp.orgi; accessed May 2004).
7. Use bridges for all permanent roadway crossings of streams and associated wetlands to eliminate the
need to fill and culvert, where practicable. If culverts must be used, the culvert should be designed to
allow passage of aquatic organisms. Generally, this means that the culvert or pipe invert is buried at
least one foot below the natural streambed. If multiple cells are required, the second and/or third cells
should be placed so that their bottoms are at stream bankfull stage. This will allow sufficient water
depth in the culvert or pipe during normal flows to accommodate movements of aquatic organisms. If
culverts are long and sufficient slope exists, baffle systems are recommended to trap gravel and provide
resting areas for fish and other aquatic organisms. If multiple pipes or cells are used, at least one pipe
or box should be designed to remain dry during normal flows to allow for wildlife passage. In addition,
culverts or pipes should be situated so that no channel realignment or widening is required. Widening
of the stream channel at the inlet or outlet of structures usually causes a decrease in water velocity
causing sediment deposition that will require future maintenance. Finally, riprap should not be placed
on the streambed. •
8. We recommend that municipalities incorporate the elements listed below into their erosion and sediment
control plans (see Brown and Caraco 2000 for additional information). Sediment is considered the
most important cause of water pollution in the United States (Waters 1995), and construction is
considered the most damaging phase of the development cycle to aquatic resources (Brown and Caraco
2000).
a) Minimize clearing and grading and only perform these operations in the context of an overall stream
protection strategy.
b) Protect waterways by preventing clearing adjacent to waterways, and stabilize drainage ways.
c) Phase construction for larger construction sites (1-25 acres) to reduce the time and area that disturbed
soils are exposed.
d) Stabilize soils as rapidly as possible (<2 weeks) by establishing a grass or mulch cover.
e) Protect steep slopes, and avoid clearing or grading existing steep slopes as much as possible.
f) Establish appropriate perimeter controls at the edge of construction sites to retain or filter concentrated
runoff from relatively short distances before it leaves the site.
g) Employ advanced settling devices that contain design features which include greater wet or dry storage
volume, perforated risers, better internal geometry, use of baffles, skimmers and other outlet devices,
gentler side -slopes, and multiple cell construction.
h) Implement a certified contractors program so that trained and experienced contractors are on -site.
Sedimentation impacts should be minimized by regular inspection of erosion control measures, and
sediment control devices should be maintained in good and effective condition at all times. Erosion and
sediment controls should be reassessed after storms. The incorrect installation of erosion control
structures and those not properly maintained can result in sedimentation impacts to nearby streams and
wetlands.
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6 May 2004
Town of Pittsboro NPDES Scoping
Project No. 04-0275
Specific Mitigation Measures for Waters Containing Federally Listed Species
Federally endangered and threatened species are particularly affected by secondary and cumulative
impacts associated with urban development due to their sensitivity to habitat degradation and resulting high
probability of extirpation. A high proportion of listed species occurs within portions of the state that are
developing the most rapidly; some have lost major reaches of their habitats within the past few decades,
others are in danger of being extirpated from entire river basins, and one species has been extirpated from
the state, and thus is extinct (Carolina Elktoe, Alasmidonta robusta). It is not just single species that are in
danger of being lost in some systems, but entire faunas and communities.
For those watersheds that support the Cape Fear shiner, the following additional conditions shall be
followed. These measures provide a higher degree of protection and also serve to protect the state -Listed
species and the general biotic integrity of these systems. The natural resource agencies' concerns regarding
indirect effects to threatened and endangered species will be alleviated by adoption of these measures.
Stormwater
1. Permits for new developments exceeding 6% imperviousness shall be required to include stormwater
controls designed to.replicate and maintain the hydrographic condition at the site prior to the change in
landscape and at a minimum include provisions that satisfy WS II-HQW minimum standards (WSII-
HQW waters as precedent; Schueler 1994; Arnold and Gibbons 1996; Doll et al. 2000; Mallin et al.
2000; May and Horner 2000; Stewart et al. 2000). This can be achieved through a variety of measures
(see Item 6 above).
2. Insufficient inforrnation exists in the literature for the minimum buffer widths necessary to ensure the
continued survival of federally endangered and threatened aquatic species. Therefore, the following
minimum buffer recommendations are based on the best scientific information available and the opinion
of biologists most familiar with the species in the state. The minimum recommended buffer widths
may actually need to be more or less stringent; and therefore, recommended widths may be modified as
more information becomes available. A 200-foot native, forested buffer on perennial streams and a
100-foot forested buffer on intermittent streams, or the full extent of the 100-year floodplain, shall be
required for new developments. Detailed studies have resulted in recommendations of 200-foot buffers
and wider for protection of priority habitats in the U. S. (Knutson and Naef 1997, and references
therein; Martin et al. 2000; Richards and Hollingsworth 2000). If wooded buffers do not exist, then
these areas shall be revegetated or allowed to naturally revegetate (so long as the area is pervious) to
increase the functionality of a forested buffer. (Knutson and Naef 1997, and references therein; 200-
foot buffers on Randleman Lake; 200-foot buffers associated with protection of aquatic endangered
species habitats required for Buckhorn Reservoir Expansion Project in 1995 — City of Wilson).
3. Grassed swales shall be used in place of curb and gutter for new developments, except in areas with
>5% slope. Check dams, level spreaders, and other associated best management practices shall be
used to minimize the effect of stormwater runoffentering the riparian buffer areas. In areas where
slopes exceed 5%, stormwater collected in piped conveyance systems shall be directed away from
surface waters and best management practices shall be employed at both the intake and the outlet areas.
Curbs and gutters may be used in combination with sidewalks in areas where clustering of uses
increases the net local density to a level greater than 4 dwelling units per acre. This will separate the
pedestrian portion of a street-scape from the automobile portion and will encourage greater pedestrian
mobility within the cluster development (see recommendations in Pedestrian Facilities Users Guide at
http://wmv.walkinginfo.org/insight/features_articles/userguide.htm; accessed May 2004). Clustering
development away from riparian areas will also allow for greater stream protection.
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Page 7
6 May 2004
Town of Pittsboro NPDES Scoping
Project No. 04-0275
4. We recommend that that direct discharges of stormwater to streams not be allowed Effective energy
dissipation at the pipe outlet shall be accomplished to prevent scour of the stream channel and buffer.
Stream habitats are maintained most effectively when stormviater runoff is dispersed through a
vegetated or grassed buffer zone prior to entering the riparian buffer. The ditching or piping of
stormwater except when used in combination with grassed swales, level spreaders and check dams shall
not be allowed in the riparian buffer. At no time should any mandated vegetated buffer zone be used
for these engineered devices. In addition, the use of trees —particularly evergreen species —can be an
effective component of an integrated stormwater management plan and can reduce the amount of
surface water runoff by as much as 7% on a site due to interception, transpiration, and other processes
(see http:IIwww.sustainable-communities.aesci.ubc.ca/bulletinslTB issue 06 forest_edit.pdf; accessed
May 2004).
5. Emergency management procedures shall provide for the containment of runoff from fighting
residential, commercial, or industrial fires and for the removal and clean up of any hazardous spills that
may endanger nearby streams, instead of flushing contaminants into waterways.
Wastewater Infrastructure
1. Force mains shall be used to the greatest extent practicable. Gravity sewer lines shall be installed to
follow along the outside of the100-year floodplain contour unless topographic features, existing
development, or other conditions restrict this technique.
2. Public and private sewer lines adjacent to streams shall parallel streams and be sited as far as
practicable from stream and tributary corridors (Knutson and Naef 1997; and references therein). A
minimum 200-foot buffer shall be provided for perennial streams and a 100-foot buffer for intermittent
streams to maintain the integrity ofthe buffer or the full extent of the 100-year floodplain. Sewer lines
close to streams shall be constructed of ductile iron or other substance of equal durability, similar to
the guidance under the general mitigation measures item number 3.
3. No new sewer lines or structures shall be installed or constructed in the 100-year floodplain or within
50 feet of wetlands associated with a 100-year floodplain (Knutson and Naef 1997; and references
therein).
4. Septic tanks, lift stations, wastewater treatment plants, sand filters, and other pretreatment systems
shall not be located in areas subject to frequent flooding (areas inundated at a 10-year or less
frequency) unless designed and installed to be watertight and to remain operable during a 10 year
storm. Mechanical or electrical components of treatment systems shall be above the 100-year flood
level or otherwise protected against a 100 year flood (As per rule 15A NCAC 18A .1950 — Location of
Sanitary Sewage Systems).
5. Only aerial crossings elevated sufficiently to reduce the risk of flood damage or directional boring
stream crossings shall be allowed. The placement of these crossings will be limited to major stream or
creek confluences. Manholes or similar access structures shall not be allowed within buffer areas.
Stream crossing areas shall be monitored once a quarter for maintenance needs.
Water and Utility Infrastructure (Electricity. Telecommunications. and Gas)
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6 May 2004
Town of Pittsboro NPDES Scoping
Project No. 04-0275
1. All water lines and utilities shall follow roads or meet the requirements associated with sewer line
placements (Killebrew 1993; Knutson and Naef 1997; and references therein). Stream crossing
guidance is presented under the general mitigation measures item number 3.
Maintenance of Rights -of -Ways
1. Insecticides and herbicides shall not be used within 200 feet of streams, floodplains, and associated
wetlands (Knutson and Naef 1997; and references therein) except when needed to protect native flora
and fauna from exotics and when using appropriately labeled products, such as biopesticides
(http://www_epa.gov/pcsticideslbionesticidcs/: accessed May 2004).
2. Native, forested plant communities shall be maintained within 200-foot buffer area of streams,
floodplains, and associated wetlands. A closed canopy will be maintained over streams. Emphasis will
be placed upon trimming trees, instead of tree removal, within 200 feet of streams, floodplains, and
associated wetlands (Knutson and Naef 1997; and references therein).
Sediment and Erosion Control
1. In addition to the items listed under the general mitigation measures, locally enforced stringent erosion
and sedimentation control requirements shall be developed and implemented for all construction. The
development of these requirements shall be fully coordinated with the state and federal agencies
involved in aquatic endangered species protection. These measures shall be state -of -the -science and
significantly exceed state minimum requirements for sediment and erosion control. Local ordinances
. shall be developed to prevent "forestry exemptions" from turning into development opportunity without
meeting the conditions identified in this memorandum.
2. Fill or buildings shall not be allowed in the 100-year floodplain (as described in previous sections).
Additional Recommendations for Federally Listed Species
1. The local government shall solicit assistance and concurrence from resource agencies such as
NCDWQ, N. C. Division of Land Resources, NCWRC, N. C. Natural Heritage Program, and USFWS
during the initial development and assessment of best management practices for stormwater
management, sediment and erosion control, utility placement, etc.
2. Maps shall be developed of the anticipated construction lines of utilities associated with expanded
service areas. This information shall become part of a Geographic Information System (GIS) database
housed and maintained by the local government. Surveys or reviews will use maps and field
determinations, when necessary, in conjunction with USACOE and NCDWQ delineation criteria for
wetlands and waters. As infrastructure or development is planned or developed, field surveys should
be conducted to assess impacts and means to avoid impacts. Field surveys (delineation) or intensive
map reviews (including soil surveys, National Wetland Inventories (NWI) maps, USGS maps,
watershed protection maps of all wetlands and waters) shall be completed and mapped with GIS
technology. All GIS databases and associated files shall be provided to state and federal agencies upon
request.
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Page 9
6 May 2004
Town of Pittsboro NPDES Scoping
Project No. 04-0275
3. Local governments shall encourage and offer incentives for new developments, as part of the
subdivision review process, to use low impact development technique for stormwater control (Low
Impact Development; EPA Document # 841— B-00-002 and 841-B-00-003), and reduce impediments
to implementing the plan. Proposed projects that are subject to NCEPA review shall identify as a part
of the subdivision review process anticipated impervious surface amounts prior to plat approval.
4. Developers and builders, including land -clearing operators, shall be required to participate in a local
government stormwater and sediment erosion control education program. Certification and bonding is
recommended.
5. Infiltration practices (e.g., reduced road widths, rain gardens, parking lot bioretention areas, increased
sheet flow instead of ditching, and disconnect impervious areas) to maintain predevelopment
hydrographic conditions shall be emphasized over detention ponds. Condition information should
include the base flow for low flow conditions.
6. Conservation Reserve Program lands and restoration of prior converted wetlands shall be encouraged
to help manage overall stormwater impacts as part of a regional integrated stormwater management
plan.
7. Site gas stations, car washes, and other "spill" land uses at least 200 feet from streams and wetlands.
8. The local government shall provide an environmental check -off list that a developer must complete
before the issuance of development approvals to ensure protection of aquatic habitats for threatened
and endangered species and that proper state and federal permits have been obtained. This shall
preclude the issuance of any subdivision plan, building, and utility permits without inclusion of
pertinent protective measures. This process shall ensure that land clearing does not occur without a
site plan, including erosion control.
9. A watershed impact evaluation board shall be established to review projects within the service area
with aquatic, endangered species. The board would ensure compliance, preview infrastructure and
development plans, and be eligible to seek funding for conservation initiatives designed to protect and
preserve aquatic, endangered species.
10. We encourage local governments to consider retrofit options, including abandonment of chronic
problem areas especially where projects exist in floodplains and are on failing septic systems. These
areas should not be candidates for sewer service. Local governments should explore all buyout
opportunities of these areas prior to exploration of providing sewer services to these areas. In addition,
this should apply to schools and other public institutions. These public facilities should be relocated to
more suitable areas. Local governments are encouraged to strengthen Local land development codes to
ensure that privates lands donated to the public for usage of schools and other public facilities (i.e. fire,
police, or medical facilities) are located outside of the 100-year floodplain so as to avoid future
problems.
11. We recommend the use of conservation easements, public ownership, or deed restrictions to ensure the
perpetual conservation of natural buffer areas.
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6 May 2004
Town of Pittsboro NPDES Scoping
Project No. 04-0275
The information provided is not sufficient for our staff to make definitive recommendations or
conclusions concerning this project. Due to staff limitations, this standardized response was developed for
projects such as this. Although some of the information, requests and comments may not be applicable to
certain projects, these guidelines should facilitate preparation of fish and wildlife impact assessments. This
information will be very useful if it becomes necessary to prepare an environmental document.
In addition to addressing the concerns discussed above, the environmental document should include
a detailed assessment of existing natural resources within these areas of potential development and should
discuss the potential of mitigating development impacts to wetlands, waters, and high quality upland
habitat. In addition, to provide a meaningful review of proposed project impacts on fish and wildlife
resources, we request that consultants, project sponsors, or permit applicants provide the following
information in the environmental document.
1. Include descriptions of fish and wildlife resources within the project area, and a listing of federally or
state designated threatened, endangered, or special concern species. When practicable, potential
borrow areas to be used for project construction should be included in the inventories. A listing of
designated species can be developed through consultation with: The Natural Heritage Program, NC
Division of Parks and Recreation, 1615 Mail Service Center, Raleigh NC 27699, PH: (919) 733-
4181.
2. Surveys should be conducted by biologists with both state and federal endangered species permits.
3. Include descriptions of any streams or wetlands affected by the project.
4. Include project maps identifying wetland areas. Identification of wetlands may be accomplished
through coordination with the U.S. Army Corps of Engineers (COE). If the COE is not consulted, the
person delineating wetlands should be identified and criteria listed.
5. Provide information on existing, planned, and projected sewer and water infrastructure service
throughout the service area. A map showing the location of the existing and projected lines and areas
containing special resources should be included.
6. Define the service area for the project, including any ETJs (extra territorial jurisdiction), and provide a
map of the service area.
7. Provide a description of project activities that will occur within wetlands, such as fill or channel
alteration. Acreage of wetlands impacted by alternative project designs should be listed.
8. Provide a description and a cover type map showing acreage of upland wildlife habitat impacted by the
project.
9. Discuss the extent to which the project will result in loss, degradation or fragmentation of wildlife
habitat (wetlands and uplands).
10. Discuss any measures proposed to avoid or reduce impacts of the project or to mitigate unavoidable
habitat losses.
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Page 11
6 May 2004
Town of Pittsboro NPDES Scoping
Project No. 04-0275
11. Discuss the cumulative impacts of secondary development facilitated by the proposed project. Such
discussion should weigh the economic benefits of such growth against the costs of associated
environmental degradation.
(a) Include specific measures that will be used to address stormwater at the source. Include specific
requirements for both residential and industrial developments and Best Management Practices (BMPs)
that will be required.
(b) Include specific measures that will be used to protect stream corridors, riparian habitat, and a
minimum of the 100-year floodplain from filling and development. Commitments by the project
sponsors to protect area streams with riparian buffers through purchase or conservation easement are
of particular interest
12. Include a list of document preparers that shows each individual's professional background and
qualifications.
Thank you for the opportunity to provide input in the early planning stages for this project. If we
can be of further assistance, please contact our office at [phone].
Literature Cited
Alexander, R. B., R. A. Smith, and G. E. Schwarz. 2000. Effect of stream channel size on the delivery of
nitrogen to the Gulf of Mexico. Nature 403:758-761.
Arnold, C. L., and C. J. Gibbons. 1996. Impervious surface coverage —the emergence of a key
environmental indicator. Journal of the American Planning Association 62:243-258. •
Brown, W., and D. Caraco. 2000. Muddy water in muddy water out? Watershed Protection Techniques
2(3):393-403.
City of Wilson. 1995. EIS for the Buckhorn Reservoir Expansion.
Doll, B. A., D. E. Wise -Frederick, C. M. Buckner, S. D. Wilkerson, W. A. Harman, and R. E. Smith.
2000. Hydraulic geometry relationships for urban streams throughout the piedmont of North
Carolina. Pages 299-304 in P. J. Wigington, Jr. and R. L. Beschta, eds. Proceedings of the
American Water Resources Association International Conference on riparian ecology and
management in multi -land use watersheds, Portland, Oregon.
EPA (U.S. Environmental Protection Agency). 2000. Model ordinances to protect local resources. EPA,
Office of Water, Washington, D.C. http://www.cpa.gov/owowwtr 1 /NPS/ordinance/index.htm
Gregory, J. D., E. Fleck, S. D. Smith, D. Penrose, J. Lawson, and R. Darling. In press. Defining,
identifying, and mapping headwater streams in North Carolina. Water Resources Research
Institute, University of North Carolina, Raleigh.
Horner, R. R., C. W. May, E. H. Livingston, and J. Muted. 1999. Impervious cover, aquatic community
health, and stormwater BMPs: is there a relationship? Proceedings of the Sixth Biennial
Stormwater Research Conference, Tampa, Florida.
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Page 12
6 May 2004
Town of Pittsboro NPDES Scoping
Project No. 04-0275
Junk, W. J., P. B. Bayley, and R. E. Sparks. 1989. The flood pulse concept in river-floodplain systems.
Pages 110-127 in D. P. Dodge, ed. Proceedings of the International Large River Symposium.
Canadian Special Publication of Fisheries and Aquatic Sciences 106, Ottawa.
Killebrew, C. J. 1993. Oil and gas activities. Pages 209-220 in C. F. Bryan and D. A. Rutherford, eds.
Impacts on warmwater streams: guidelines for evaluation. Southern Division, American Fisheries
Society, Little Rock, Arkansas.
Knutson, K. L., and V. L. Naef. 1997. Management recommendations for Washington's priority habitats:
riparian. Washington Department of Fish and Wildlife, Olympia.
Kwon, H. 2000. An introduction to better site design. Watershed Protection Techniques 3(2)623-632.
Mallin, M. A., K. E. Williams, E. C. Esharn, and R. P. Lowe. 2000. Effect of human development on
bacteriological water quality in coastal watersheds. Ecological Applications 10(4):1047--1056.
Martin, C. O., R. A. Fischer, and H. H. Allen. 2000. Riparian issues on Corps of Engineers and DOD
Military Lands. Pages 317-322 in P. J. Wigington, Jr. and R. L. Beschta, eds. Proceedings of the
•American Water Resources Association International Conference on riparian ecology and
management in multi -land use watersheds, Portland, Oregon.
May, C. W. and R. R. Horner. 2000. The cumulative impacts of watershed urbanization on stream -
riparian ecosystems. Pages 28 i 286 in P. J. Wigington, Jr. and R. L. Beschta, eds. Proceedings
of the American Water Resources Association International Conference on riparian ecology and
management in multi -land use watersheds, Portland, Oregon.
MDE (Maryland Department of the Environment). 2000. 2000 Maryland storntwater design manual,
volumes I and II. Center for Watershed Protection and MDE, Water Management Administration,
Baltimore, Maryland. http://www.mdc.statc.md.us/environment/wmaistormwatcrmanual/
Naiman, R. J., H. Decamps, and M. Pollock. 1993. The role of riparian corridors in maintaining regional
biodiversity. Ecological Applications. 3(2):209-212.
Palik, B. J., J. C. Zasada, and C. W. Hedman. 2000. Ecological principles for riparian silviculture. Pages
233-254 in E. S. Verry, J. W. Hornbeck, and C. A. Dolloff, eds. Riparian management in forests
of the continental eastern United States. Lewis Publishers, Boca Raton, Florida.
Paul, M. J., and J. L. Meyer. 2001. Streams in the urban landscape. Annual Review of Ecology and
Systematics 32:333-365.
Peterson, B. J., W. M. Wollheim, P. J. Mulholland, J. R. Webster, J. L. Meyer, J. L. Tank, E. Marti, W.
B. Bowden, H. M. Valett, A. E. Hershey, W. H. McDowell, W. K. Dodds, . S. K. Hamilton, S.
Gregory, and D. D. Morrall. 2001. Control of nitrogen export from watersheds by headwater
streams. Science 292:86-90.
Richards, C., and B. Hollingsworth 2000. Managing riparian areas for fish. Pages 157 168 in E. S.
Verry, J. W. Hornbeck, and C. A. Dolloff, eds. Riparian Management in Forests of the
Continental Eastern United States, Lewis Publishers, Boca Raton, Florida.
Schueler, T. 1994. The importance of imperviousness. Watershed Protection Techniques. 1(3):100-111.
{, T • d T t Si-64fi-9EE
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6 May 2004
Town of Pittsboro NPDES Scoping
Project No. 04-0275
Stewart, J. S., D. M. Downes, L. Wang, J. A. Wierl, and R. Bannerman. 2000. Influences of riparian
corridors on aquatic biota in agricultural watersheds. Pages 209-214 in P. J. Wigington, Jr. and
R. L. Beschta, eds. Proceedings of the American Water Resources Association International
Conference on riparian ecology and management in multi -land use watersheds, Portland, Oregon.
Van Sickle, J. 2000. Modeling variable -width riparian buffers, with an application to woody debris
recruitment. Pages 107-112 in P. J. Wigington, Jr. and R. L. Beschta, eds. Proceedings of the
American Water Resources Association International Conference on riparian ecology and
management in multi -land use watersheds, Portland, Oregon.
Waters, T. F. 1995. Sediment in streams: sources, biological effects, and control. American Fisheries
Society Monograph 7, Bethesda, Maryland.
Thank you for the opportunity to provide input during the planning stages for this project. If we
can be of further assistance, please contact our office at (336) 449---7625.
cc: David Rabon, USFWS
Michael Hosey, USACOE
E-mail: Sarah McRae, NHP
Brian McRae, WRC
Keith Ashley, WRC
Ryan Heise, WRC
Rob Nichols, WRC
Issac Harrold, WRC
S I• d i t St►- Gist,-9EE
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l7�s4- SUM N
i
NK '3 2 4
DEPARTMENT OF ENVIRONM T.:AND ::
NATURAL RESOURCES"
-7
DIVISION OF ENVIRONMENTALHEALTH •
Inter -Agency Project Review Response
fro/,'sed P,OEjProect Name ype of Project
P 'fit
si®!�'p
Comments provided by:
Project Number
CcAty7rja4,77
❑ Regional Program Person •
csi Regional Engineer for Public Water Supply Section
❑ Central Office program person
Name. 1,-
1
Telephone number: 11 4 7:
Program within Division of Environmental Health:
❑ Public Water Supply •
❑ Other, Name of Program:
Response (check all applicable):
❑ No objection to project as proposed
❑ No oomment.
❑ Insufficient information to complete review
❑ Comments attached
[-See comments below •
•
Date: 4
•
1/0"i•
• t Return to:
Public Water Supply Section
Environmental Review Coordinator
for the
Division of Environmental Health
•
w
APR 2 2 2004
PUBICWAt Ia• 1vIINITIN

Re: Pittsboro
Subject: Re: Pittsboro
From: Dave Goodrich <[e-mail]>
Date: Mon, 03 May 2004 06:43:48 -0400
To: Susan Wilson <[e-mail]>
I think we can get Pittsboro to request the flows from Curtis. Seems like it might be a little
premature, though?
Susan Wilson wrote:
Dave -
Should i request flows for that portion of the Haw? didn't know if i should based on
potential controversy. (we had discussed this as a larger issue during a staff meeting
and i think we.decided just to use equations if the equations were in place?) but, since
this may be an issue - i wasn't sure how to handle it.
also - Alex will likely speak with you on Friday. Parks hates their proposed location
because they own the land surrounding the area - so Michelle told them a discharge
further downstream or to the Lake was a possibility!! what the fudge? i spoke with her
about it after Alex told me - i don't understand why she said that, still.
1 of 1 5/3/2004 11:10 AM

TOWN OF
NANCY R. MAY
Mayor
DAVID B. HUGHES, P.E.
Town Manager
PAUL S. MESSICK, JR.
Town Attomey
P.O. Box 759 — 635 East Street
PTTISBORo. N.C. 27312
March 19, 2004
Ms. Susan Wilson
NPDES Permit Section
DWQ, NCDENR
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Town of Pittsboro
Request for Speculative Waste Load Allocations
Dear Ms. Wilson:
BOARD OF COMMISIONERS
GENE BROOKS
MAX G. COTTEN
BURNICE N. GRIFFIN, JR.
CHRIS WALKER
CLINTON E. BRYAN, JR.
TELEPHONE
[phone]
FAX [phone]
The Town of Pittsboro is beginning the environmental document process necessary to
explore a possible NPDES permit location on the Haw River, between U.S. Hwy. 64 and
U.S. Hwy. 15/501. To assist in this process the Town requests speculative waste load
allocations be prepared for the site indicated on the enclosed map.
At this point the Town has not yet determined the size of the proposed discharge,
although we believe it will be between 4.0 and 6.0 MGD. For the purposes of the waste
load allocations, please provide speculative limits for both of these flows.
Please call me or John Phillips, P.E. at Diehl & Phillips (919-467-9972) if you have any
questions regarding this request. We appreciate your continued assistance in this matter.
CC: John F. Phillips, P.E.
Yours truly,
David B. Hughes, P.E.
Town Manager
CHARTERED 1787

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1IJ U A TZ,„ Michael F. Easley, Governor
•
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
January 12, 2004
David Hughes, P.E.
Town Manager
Town of Pittsboro
P.O. Box 759
635 East Street
Pittsboro NC 27312
Subject: Draft water quality assessment for portions of the Haw River and Cape Fear River
Dear Mr. Hughes,
As indicated at the October 31, 2003 meeting, the use support assessment for the Cape Fear
River basin has not been completed for the assessment period starting September 1, 1998 to
August 31, 2003. The water quality assessment and assignment of use support ratings will not be
completed until late summer 2004. However, data and some of the information to be used in the
water quality assessment has been collected and is currently being processed by DWQ staff.
Because this information is important for you to consider in locating a discharge site, DWQ staff
have developed draft use support ratings. Although we cannot provide you with final use support
ratings in the applicable use categories at this time, we can provide the following summary of
data and information that will be used to make use support assessments and assign use support
ratings. The draft use support ratings discussed below will not be considered final until after
public review in April 2005 and approval by the Environmental Management Commission in
August 2005.
The water bodies under consideration are summarized in the attached map as segment numbers 1
through 10. The attached table defines each segment with an assessment unit number (class ID),
segment description, water quality classification, data points applied to each segment and brief
notes on water quality concerns in each segment. Each segment is discussed in more detail
below including a draft use support rating and an explanation of the criteria and data application.
Segments 1 and 2
Dissolved oxygen saturation was above the water quality standard of 110% in 24.4 percent of
samples collected from 1/30/97 to 8/21/03 at DWQ ambient station B2100000 at Hwy 15 Bridge.
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone]
Customer Service
1-877-623-6748
1 of 3

As you have likely surmised from the information stated in this letter, the draft use support
assessment indicates that the riverine portion of the Haw River appears to be the most feasible
area for a discharge (generally around the area outlined by Segment 3 of the attached map).
However, DWQ anticipates keen public interest regarding any proposed discharge in this area.
As has been discussed, recreational boaters use this segment of the Haw River extensively. If
this location is chosen, DWQ believes that the Town of Pittsboro should plan on gathering public
input early and often during the planning process.
Any nutrient management strategy and TMDL for the Haw River Arm of Jordan Reservoir will
have to include the Town of Pittsboro discharge. Please work with our NPDES Unit staff once
the Town determines the most feasible option for a discharge and expansion.
Sincerely,
tp€7-
oleen Sullins
Deputy Director
Division of Water Quality
Cc: Boyd Devane
Dave Goodrich
Michelle Woolfolk
Dianne Reid
Darlene Kucken
Steve Kroeger
Cam McNutt
Susan Wilson
Trish MacPherson
Todd Kennedy
3 of 3

v
B245000

Segment
#
Waterbody
AU number
Description
Classification
Data Point
Notes
1
Haw River
16-(28.5)
From .4 mile downstream of
Cane Cr (South sid of Haw R.)
to .4 mi downstr of brooks br.
WS-IV NSW
B2100000
DO saturation exceed criterion in
24.4% of samples
2
Haw River
16-(36.3)
From .4 mi downstr of brooks
br. to Pittsboror WSI (.3 mile
upstream of Pokeberry Cr)
WS-IV NSW CA
B2100000
DO saturation exceed criterion in
24.4% of samples
3
Haw River
16-(36.7)a
From Pittsboro WSI (.3 mile
upstream of Pokeberry Cr) to 1.5
mile upstream of US Hwy 64
WS-IV NSW
B2210000 and
Benthic site
No Criteria exceeded and Good
Benthic sample in 2003
4
Haw River
16-(36.7)b
From 1.5 mile upstream of US
Hwy 64 to .5 mile downstream of
US Hwy 64
WS-IV NSW
B2210000 and
Benthic site
No Criteria exceeded and Good
Benthic sample in 2003 and in
model segment 15 (12%
chlorophyll a exceedence in
model)
5
Haw River
16-(37.3)
From .5 mile downstream of US
Hwy 64 to 1 mile below US Hwy
64
WS-IV NSW CA
TMDL study
model segment 15 Chlorophyll a
criterion exceeded in 11 % of
samples (12% in model)
6
Haw River (B.
Everett Jordan Lake
below n. pool elev.)
16-(37.5)
From 1 mile below US Hwy 64 to
dam at B Everett Jordan Lake
WS-IV&B NSW CA
TMDL study
model segment 14 Chlorophyll a
criterion exceeded in 15% of
samples (16% in model)
7
Haw River
16-(42)
From dam at B. Everett Jordan
Lake to Cape Fear River
(Junction with Deep River)
WS-IV
B4050000 and
B4080000
no criteria exceeded but limited
because of B6160000
8
Cape Fear River
18-(1)
From junction of Haw and Deep
R to .5 mile upstream of NC Hwy
42
WS-IV
B6160000
DO saturation criterion exceeded
in 27.8% of DWQ samples and in
37.2% of Coalition samples and
Chlorophyll a criterion exceeded
in 14.8% of samples
9
Cape Fear River
18-(4.5)
From .5 mile upstream of NC
Hwy 42 to NC Hwy 42 (Sanford
WSI)
WS-V
B6160000
same as 8
10
Cape Fear River
18-(5.5)a
From NC Hwy 42 to Buckhorn
Dam
WS-V
B6160000
same as 8

Re: [vd: Re: Pittsboro letter]
• 4
Subject: Re: [Fwd: Re: Pittsboro letter]
From: Dave Goodrich <[e-mail]>
Date: Wed, 10 Dec 2003 15:51:00 -0500
To: Darlene Kucken <[e-mail]>
CC: cam mcnutt <[e-mail]>, Michelle Woolfolk
<[e-mail]>, Susan Wilson <[e-mail]>
Darlene & Cam -
Susan will be our reviewer and point of contact on this.
Thanks,
Dave
Darlene Kucken wrote:
Cam - Can you please put together a draft letter and send it on to Michelle, Dave and I
for review? In addition to presenting the relevant information - you need to put in a
paragraph that this is data results compiled to address Pittsboro's concerns and
questions but that we have not done a use support assessment and relate the schedule
for plan development, highlighting the public input stages.
Dave - you'll need to add your permitting perspective on this one.
All - the note I got from Coleen was that she wanted this response to be done in as . short
a time frame as possible.
Original Message
Subject:Re: Pittsboro letter
Date:Wed, 10 Dec 2003 15:00:50 -0500
From:Coleen Sullins <[e-mail]>
To:Darlene Kucken <[e-mail]>
CC:cam mcnutt <[e-mail]>, Boyd Devane
<[e-mail]>, Trish MacPherson
zI,[e-mail]>, Steve Kroeger
<[e-mail]>, Michelle Woolfolk
<[e-mail]>, Dave Goodrich
<Dave. Goodrich@ncmail. net>
References:<3FD74050.4000801 @ncmail. net>
How about getting with Michelle and Dave and drafting a response to the letter. Thanks
Coleen
Darlene Kucken wrote:
Coleen -
This email refers to the letter from David Hughes of Pittsboro.
Steve and Trish did some analysis on the data we have for the 5-year window that will
be used in the next assessment report and the next use support evaluation.
Ambient Data Summary
Stations B2100000 (Haw R. at Bynum) and B2210000 (Haw R. at US 64) have the most
1 of 2 12/ 11 /2003 6:41 PM

Re: [Fwd: Re: Pittsboro letter]
data There is some data from two other stations (B2130000 and B2140000 -- both
near Bynum) but one station has no field measurements, and both stations are very
limited in time.
DWQ has sampled from B2100000 for a long time, and the most contiguous block of
data begins in 1980. DWQ sampled B2210000 from the late 1960s to early 1980, then
there are a few data points in 1996. The UCFRBA began sampling here in April 2000.
Steve developed some plots and summaries of all the data. We then narrowed down
the review to the 5-year window and specific parameters of interest for use support (see
attatchment).
We would not impair these two sites based on DO.
%DO Saturation - 24.% of 82 samples >110 (could be an impairment question, but
definitely a concern); NO2+NO3 values are high - but not an impairment issue.
Fecal values exceed the 400/100 portion of the standard, but unless we do 5/30
sampling we wouldn't impair on this.
Benthic Data Summary
The Haw River at US 64 near Pittsboro is a basinwide benthos site. Due to continuous
high flows in 2003, it could not be sampled. Fortunately, it was sampled in October
2002 as part of a drought study and it got the same Good bioclassification that it. has
gotten since 1985 (7 samples). Despite low DO values that you noted below, this:
section ofriver is clearly supporting aquatic life uses. The next upstream site is SR •
1005 in Alamance Co. It was also sampled in October 2002 and got a Good -Fad
bioclassification. This is the same rating it has had since 1984. We have no fish
data -river is too large for IBI work.
So there are concerns for water quality in this area and those concerns may increase .if
there were a discharge. There are things that would have to be worked out in the
permit. But unless we pursued the % DO Saturation or fecal sampling, we would not
have cause to impair this segment.
Coleen - what do you want to do with this information?
2 of 2 12/ 11 /2003 6:41 PM

DIVISION OF WATER QUALITY
November 20, 2003
To: Alex Marks
Local Government Assistance Unit
From: Susan A. Wilson, Environmental Engineer
NPDES Unit
kia
Subject: Town of Pittsboro WWTP, Environmental Assessment
NPDES No. NC0020354
Chatham County
I have reviewed portions of the Environmental Assessment (EA) for the proposed
wastewater improvements for the Town of Pittsboro. It is our understanding that the
proposed project (first phase) consists of the upgrade of the wastewater treatment plant
to comply with the rules imposed for re -use quality effluent. The Town plans to provide
re -use quality water to 3M, Incorporated as well as pursue other opportunities for re-
use wastewater. The NPDES Unit has no objection to upgrade of the existing treatment
plant to comply with re -use standards, as well as the addition of storage and pipeline to
transport the re -use water.
The NPDES Unit is working with the Town of Pittsboro to determine the best point of
discharge as the Town plans for future expansion. Currently e o n discharsSesjp
Robeson Creek, whi .h j impaired for chinrnptlyll a. total m
(TMDL) has been developed for total phosphorus (the..prevalent caus.e.of..the.nutrient
impairment). The total phosphorus equivalent concentration .th.at.the-To_wn.wilLhave„to
'mc'et may -riot -be technologically_ fe ' e, so another dischargelocation is likely. the best
option for the Town. _
The NPDES Unit reserves comment on any expansion phase of the treatment system
(an expansion phase option is explained in the document for 2008 Improvements and
2015 Improvements). As the Town and the NPDES Unit work together to determine the
best course of action for expansion and/or relocation of the discharge, the NPDES Unit
will request an Engineering Alternatives Analysis, as well as any other supporting
information.
The NPDES Unit has no further comment on this EA and does not wish to delay this
beneficial re -use project.
cc: Central Files
NPDES Files
RRO/ Water Quality Section
CG & L Section

TOWN OF
NANCY R. MAY
Mayor
HUGH R. MONTGOMERY
Town Manager
PAUL S. MESSICK, JR.
Town Attomey
P.O. Box 759 — 635 East Street
PI TSBORO. N.C. 27312
D OF COMMISIONERS
NOVO iQQ3 GENE BROOKS
ggll MAX G. COTTEN
DIV. OF WATER QUALIBURNICE N. GRIFFIN, JR.
DIRECTOR'S OFFICE CHRIS WALKER
CLINTON E. BRYAN, JR.
Ms. Coleen Sullins
Section Chief Division of Water Quality
North Carolina Department of Environment and Natural Resources
1617 Mali Service Center
Raleigh, NC 27699-1617
Re: Haw River Data Analysis
Dear Ms. Sullins,
November 5, 2003
TELEPHONE
[phone]
FAX [phone]
This letter is being sent to expedite the analysis of data taken on the Haw River in the area
between the Bynum Bridge and U.S. Hwy 64 east of Pittsboro. As you may know, I recently had
a meeting with several members of the Division of Water Quality staff to discuss the Town of
Pittsboro's options for wastewater discharge. The DWQ staff at the meeting included Dave
Goodrich, Susan Wilson, Todd Kennedy and Cam McNutt. Currently a TMDL strategy for
Roberson Creek, Pittsboro's discharge location, has been submitted to the EPA for review. It is a
certainty that Pittsboro's current discharge into Roberson Creek will change as a result of the
TMDL. The details of the change or the implementation period have yet to be determined but the
nature of Pittsboro's discharge will be seriously altered. In view of this and the need for additional
capacity, Pittsboro has begun the task of seeking another discharge location.
A prior meeting was held on July 10, 2003 between the Town of Pittsboro and the DWQ staff
to discuss these same issues. At that meeting a possible discharge to the Haw River between
the Bynum Bridge and U.S. Hwy 64 was presented. Our meeting on October 31, 2003 was a
follow up on this same issue. At that meeting we were told that some recent sampling at the
Bynum Bridge showed some possible elevated dissolved oxygen readings. The details of the
data and the additional background information concerning this data have not been analyzed.
D.O. readings taken at the same time at U.S.Hwy 64 were believed to be within normal
parameters. No other information or explanation was presented. Mr. Goodrich stated that there
were no immediate plans for further analysis of this data and it could be an extended period of
time before that analysis was done.
I would request that this analysis be given a high priority. With the TMDL for Roberson Creek
looming, Pittsboro has little alternative but to seek another discharge location. At this point in
time the Haw River may be the most viable location for that discharge. If it is not then we need to
know that as soon as possible and investigate some other locations. It is imperative that a
discharge location be determined in the very near future and your assistance is critical. Please
let us know what the timetable will likely be for at least a preliminary determination of a feasible
discharge location.
Your assistance in this matter is greatly appreciated.
Sincerely,
David B Hughes, P.E.
Town Manager
(5,9`\"1
CHARTERED 1787

itiWN OF
NANCY R. MAY
Mayor
DAVID B. HUGHES, P.E.
Town Manager
PAUL 5. MESSICK, 3R.
Two Attorney
P.O. lox 759 — 635 East Street
P1T1510RO. N.C. 27312
July 21, 2003
Mr. J Todd Kennedy
-Water Quality Ping Branch
NC Division ofWaterQtity
1617 Mali Service Center
Raleigh NC 27699-1617
Re: Public Camnerdfor draft Roberson Creek TMDL
BOARD OF OOMMISIONERS
GENE BROOKS
MAX G. COTTEN
BURNICE N. GRIFFIN, iR.
axIS WALKER
CLINTON E. BRYAN, 3R.
TELEPHONE
[phone]
FAX [phone]
Dear Mr. Kennedy:
This letter is forwarded for the Purpose of praricling comment as It relates to the subject draft TMDL
These comments are based on a {united review of the draft TMDL �� ixesentalion
�,
at the public meeting July 15, 200a. Because of this unitedadditional
objections or observations could be forthcoming from the Town of Pittsboro. The filming are some
connects for your consideralion.
• lithe criteria for P is based on 10% comedowns for atypical year and the model is based on a dry
year (non -typical), itwould seem that the allele be overly conservative. Itwould also seem
that an added margin of safely Is even more conservative
• If lbw data was underestimated, ham would that effect ? Line 2 on page 24 states, The
true value of load can only be determined with continuous flow and conoentratlon records.'
• The last paragraph on page 31 states that "since a term for %It
s not
tiincluded
n and has candidate
models, predicted chi a may be overestimated. What is this
calibration factor accurately account for this?
• What does paragraph 3 and 4 of section 4.4, page 48, mean and vAiat Is lack of agreement
between the models?
• The footnote beta" the chart on page 9 mentioned data is uncorrected for pheophytin which may
overestimate the actual corrected valve. What are the rant is O' ns of this?
• Why was the BATHTUB model used in this study versus the WASPIEUTROS model used for the
Jordan Lake Nutrient Response study done by TETRA TECH, INC.?
• Mat otherWWTP's have had TMDL's for either P or N applied to them?
• What were the limits that were applied?
CHARTERED 1787
�.,wA q
!k 7123
Sf
AS 7/a

• Page2 July 22, 2033
• Were any of the plants comparable in size to Pittsbords plant??
• What Mara the phase -in periods for canpliance t0 the new ts?
• The bnplevrentation schedule' must recognize the Tom's limbed financial capabilities, and must
allow suflident time for the Tan to obtain findng necessary to upgrade the plant to achieve the
proposed Phosphorus limitations. The tarn should be given an implementation time period that is
at least as long as the one provided to the dischargers in the Neuse Basin when the TN limit was
imposed there.
• The model used to develop the TMDL for Robeson Creek was based on data collected in a limited
time period, and during a period when a non-disdhage system was fined for runoff from a spray
irrigation site. These events may have affected the accuracy of the model, and the Town therefore
requests the Division ofWaterQusii(y continue to monkor stream flow, and periodically sample and
check the observed chlorophyll a with the model -predicted value. If the results indicate the model
has required a lager TP reduction from the Tare's treatment plant than Is actualy neoessary to
maintain the stream stands, we would then request the Division revise the TMDL to aloes a
larger TPA.
• In the pubic meeting it was disarmed that the Division is proposing the massbased TP Ord
from the TMDL model be implemented from April I -- October 31, and that the adding 2.0 mgll
quarterly average remain in placeforthe remaining months. The Tarn supports this proposal.
As stated previously, these commerts are not all indusive but they do address several
issues the Town of Piitsboro is concerned with, We look forward to working with the Div ion of Water
Quality in deal'mg with these difficult issues. Thank you for your time and consideration of these
comments and we look forward toyour response.
B. Hughes, P. E.
Tarn Manager
DRH.:cgs

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
Now Available Upon Request
Total Phosphorus Total Maximum Daily Load for Roberson Creek
Public Review Draft — June 2003
Is now available upon request from the North Carolina Division of Water Quality. This
TMDL study was prepared as a requirement of the Federal Water Pollution Control Act,
Section 303(d). The study identifies the sources of pollution, determines allowable
loads to the surface waters, and suggests allocations for total phosphorus.
TO OBTAIN A FREE COPY OF THE TMDL REPORT:
Please contact Mr. J. Todd Kennedy [phone], extension 514 or write to:
Mr. J. Todd Kennedy
Water Quality Planning Branch
NC Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
The draft TMDL is also located on the following website: http://h2o.enr.state.nc.us/tmdl.
Interested parties are invited to comment on the draft TMDL study by July 21, 2003.
Comments concerning the report should be directed to Mr. J. Todd Kennedy at the
above address.
Public Meeting Notice
A public meeting to discuss the
Roberson Creek TMDL
will be held on July 15 at 10 AM
at the following address:
Chatham County Agricultural Center Auditorium
45 South Street, Pittsboro NC 27312
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
N DENR
Customer Service
1 800 623-7748

Roberson Creek TMDL Public Review DRAFT
3. TMDL Information
Critical condition: Hydrologically dry conditions; summer algal growing season
Seasonality: TMDL is based on meeting the target standard during the critical summer growing
season. The TMDL is applied on an annual basis. Weather related variability during the model
year is incorporated.
Development tools: FLUX, BATHTUB, SWAT
Supporting documents: Total Maximum Daily Load (TMDL) For Total Phosphorus, NC
Division of Water Quality (2003)
TMDL
Total mass daily load allocation of total phosphorus in kilograms (kg).
Source Types
TMDL for
Summer
% reduction
from Table
3.7
TMDL for
Winter
% reduction
from Table
3.7
Totals (kg)
A. Without Back ground
source
1. Non -point source
Urban
44
71
236
71
280
Forest
_
100
71
100
Pasture/Hay lands
_
73
71
73
2. Point source
WWTP
146
71
115
71
261
Total
189
524
713
B. With Back ground source
1. Non -point source
Urban
44
71
91
89
135
Forest
_
344
0
344
Pasture/Hay lands
_
35
86
35
2. Point source
WWTP
146
71
53
87
199
Total
189
524
713
Loading allowed at critical condition: 713 kg TP/year (1.96 kg TP/day)
Wasteload Allocation (WLA): 199 kg TP/year (0.55 kg TP/day)
Load Allocation (LA): 514 kg TP/year (1.41 kg TP/day)
Margin of Safety (applied to the water quality criteria): An explicit margin of safety of 7.9 µg/L
chlorophyll a based on meeting the lower 80% confidence interval of receiving water model
11i

Roberson Creek TMDL Public Review DRAFT
5 Implementation Plan
The TMDL analysis was performed using the best data available to specify the nutrient reductions
necessary to achieve water quality criteria; the chl a target in this lower portion of Roberson
Creek. The intent of meeting the criteria is to support the designated use classifications in the
watershed. The decision to focus on P was based on the assumption that P will ultimately control
growth in the cove and reductions in P will drive the cove to an increasingly P limited state (by
increasing the N:P ratio). As a practical matter, some reductions of N will likely accompany P
reductions. This is desirable from a management perspective because although N is not the
primary limiting nutrient during most of time, loading of N does contribute to algal growth in the
cove. Further, downstream waters such as Jordan Lake may be affected by N contribution from
this watershed. Therefore, an increase in N loading would not be recommended.
An detailed implementation plan is not included in this TMDL. The involvement of local
governments and agencies will be needed in order to develop the implementation plan. During
2002, the NCSU Water Quality Group received a EPA Section 319 grant to perform a watershed
assessment of the Roberson Creek watershed. Part of the project will involve identification of
areas for targeting of best management practices (BMP) within the watershed.
6 Stream Monitoring
Monitoring will continue on a monthly interval at the ambient monitoring site in the Roberson
Creek Cove. The continued monitoring of nutrient and chl a concentrations will allow for the
evaluation of progress towards the goal of achieving water quality standards.
7 Future Efforts
Overall, the reduction of TP required to meet the chl a standard at the Roberson Creek cove was
464 kg and 1284 kg during summer and winter seasons, respectively. Nutrient loading will vary
year-to-year based on changes in flow regime. The allowable TP load to the Roberson Creek
52

Roberson Creek TMDL Public Review DRAFT
Cove is based on an identified critical condition for nutrient enrichment: a dry hydrologic period
during the algal growing season. Dry hydrologic conditions in Roberson Creek Cove would tend
to maximize residence time and nutrient retention, thereby promoting algal growth (Wetzel
2001). Further monitoring and modeling may be desirable in the future to confirm these
assumptions. Future work should include an enhanced characterization of the relationship
between flow and nutrient concentrations across a range of hydrologic conditions. Likewise, an
analysis of eutrophication response during wetter years may be useful.
8 Public Participation
A draft of the Roberson Creek TMDL will be publicly noticed through various means, including
notification in the local newspaper, The Chatham Record. DWQ will electronically distribute the
draft TMDL and public comment information to known interested parties. The TMDL will also
be available from the Division of Water Quality's website at
http://h2o.enr.state.nc.us/tmdl/draft TMDLs.htm during the 30-day comment period beginning
June 19. A public meeting will be held on July 15 (10 AM) at the Chatham County Agricultural
Center Auditorium in Pittsboro. At this meeting, staff will present the TMDL and offer the
opportunity for public questions and comments.
53

Re: Internal Review Draft - Roberson Ck. TMDL
a'
Subject: Re: Internal Review Draft - Roberson Ck. TMDL
Date: Wed, 21 May 2003 09:37:52 -0400
From: "J. Todd Kennedy" <[e-mail]>
Organization: NC DENR DWQ
To: Dave Goodrich <[e-mail]>
CC: Michelle Woolfolk <[e-mail]>,
Susan A Wilson <[e-mail]>
OK but we're on a tight schedule here (you know me). Let's say comments, if any, to me by Monday PM
(the 9th). Thanks for your coorperation.
-Todd
Dave Goodrich wrote:
Todd -
Susan's the person that I'd like to have review this document. She's out of town until June 5th. She's
been in recent contact with Pittsboro and has had multiple meetings with them in the past. There really
isn't anyone else who's kept up with this situation in the Unit (including me), so I'd ask that. we wait until
she returns before rolling this out.
Thanks,
Dave
"J. Todd Kennedy" wrote:
Regarding previous email,
Sue- please review portions regarding Townsend Foods and potential implications, if any, for their
permit.
Dave- note this tmdl will probably affect Pittsboro's discharge limits.
Thanks.
-Todd
"J. Todd Kennedy" wrote:
The Roberson Creek TMDL for total phosphorus is ready for internal review. See attached file. Let
me know if you would like for me to deliver a hard copy. Please send comments by June 2 (2 week
review). Thank you.
J. Todd Kennedy
NCDENR/Water Quality/Planning
J. Todd Kennedy
1 of 2 6/13/03 4:00 PM

Re: pittsboro
Subject: Re: pittsboro
Date: Tue, 08 Jul 2003 08:46:29 -0400
From: "J. Todd Kennedy" <[e-mail]>
Organization: NC DENR DWQ
To: Susan A Wilson <[e-mail]>
CC: Michelle Woolfolk <[e-mail]>,
narayan rajbhandari <[e-mail]>
Susan A Wilson wrote:
did we agree on a summer period? Yes
are we sticking with 146 kg (from
April 1 through September 30)? Yes but summer is defined in the Roberson document as Apr 1-
Oct 313
and we were not going to make them meet a winter value? No but going with the HB 515 limits per
MW which I believe is the 2 mg/I
Thanks.
J. Todd Kennedy
NC DENRIWater Quality/Planning
919.733.5083 x514
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Re: [Fwd: [Fwd: from connie allred/rocky river]]
Subject: Re: [Fwd: [Fwd: from connie allred/rocky river]]
Date: Wed, 12 Feb 2003 14:22:22 -0500
From: Elizabeth_Kountis <[e-mail]>
Organization: NC DENR DWQ
To: Susan A Wilson <[e-mail]>
CC: Tom Reeder <[e-mail]>, Dave Goodrich <[e-mail]>
I take it that Dave forwarded you my e-mail regarding a call that I got yesterday
from a landowner along the
Rocky River concerned about this discharge in relation to the proposed Rocky River
reclas. Just as a reminder:
DWQ did receive a request to reclassify a portion of the Rocky River to WS-III CA.
The proposed CA would extend
along the current river from the proposed dam, which is to be placed approximately 65
feet downstream of the
existing dam (that is very near to current Siler City intake), to a point
approximately 3.6 miles upstream of
the proposed dam. A NRP has already been published for this request, and I will be
going to EMC tomorrow to ask
for permission to go to public hearing (probably sometime this summer). Please keep
me updated on this
discharge. Thanks
Susan A Wilson wrote:
> Folks,
> The Town of Pittsboro has been seeking expansion possibilities for some time.
Currently, they are
> discharging to a 303 d listed stream. We provided them with some very, very
limited
> possibilities/alternatives for expansion at the existing site (probably a couple of
years ago). I spoke
> with their consultant in December 2002 re. possible sites for expansion (besides
the existing site and even
> other sites are very, very limited). The consultant wondered if Rocky River was a
possibility. I informed
> him of the endangered species issue and the dam issue. As usual with any request
for speculative limits, we
> will have to look into the modeling/WQ issues (I could not tell him over the phone
of any restrictions due
> to WQ modeling because I was not in a position to research it at that time). We
received a request for
> speculative limits on Rocky River and the Deep River in mid -January of this year
(and I believe they sent a
> request for scoping assistance to the clearing house). I have not had a chance to
dig into it at all yet -
> but I'm sure Michelle and I will be talking. If WQ issues are a constraining
factor - the consultant and
> the Town will be notified via letter. I fully informed the consultant of the major
hurdles to overcome with
> re. to WRC and the endangered species issue (as well as the possibility of minimum
release issues with the
> dam).
> Give me a ring if you have questions - but likely I won't be able to answer until I
dig into it further.
> Thanks.
> Susan
> Dave Goodrich wrote:
1 of 3 2/ 12/03 2:47 PM

Re: [Fwd: [Fwd: from connie allred/rocky river]]
> > Please respond to Alan (it's Pittsboro Day, apparently). Thanks.
> >
> >
> >
> > Subject: (Fwd: from connie allred/rocky river]
> > Date: Wed, 12 Feb 2003 08:43:47 -0500
> > From: Alan Clark <[e-mail]>
> > To: Michelle Wool folk <[e-mail]>,
> > Dave Goodrich <[e-mail]>
> >
> > Hi folks. I've received an inquiry and concern regarding Pittsboro's
> > WWTP expansion. Could the two of you briefly update on the what's
> > happening with Pittsboro and whether they're really contemplating a
> > discharge to the Rocky River.
> >
> > Thanks, Alan
> >
> >
> >
> > Subject: from connie allred/rocky river
> > Date: Wed, 12 Feb 2003 01:49:39 GMT
> > From: [e-mail] (Herb &Connie Allred)
> > To: [e-mail]
> >
> > Hi Alan,
> >
> > Hope you are well. As you may already know, The Town of Pittsboro is
> > planning to enlarge their waste water treatment plant. Along with the
> > expansion, they are also contemplating a new discharge site into the
> > lower Rocky River. How can this be seriously considered? Aside from
> > the fact that this area is Federally Designated Habitat for the Cape
> > Fear Shiner, there was also modeling done when Siler City was
> > expanding their WWTP that showed that the Rocky River could not
> > tolerate any additional nitrogen. I believe that the modeling
> > predicted, based on the amount of nitrogen released under Siler City's
> > current NPDES permit, that there would be dissolved oxygen sags in the
> > downstream Rocky River. This modeling was also based on the erroneous
> > assumption that Siler City would not violate their NPDES permit.
> > These are just a few of the obvious reasons why an additional point
> > source discharge of millions of gallons into the Rocky is an absurd
> > idea. I would like to review all drafts of the pending EIS. Who
> > should I contact for access to those drafts? Thanks for your help.
> >
> > Connie Allred
> >
> >
> >
> > Alan Clark <[e-mail]>
> > Environmental Supervisor
> > NC Division of Water Quality, Planning Branch
> > Dept. of Environment and Natural Resources
> >
> > Alan Clark
> > Environmental Supervisor
<[e-mail]>
> > NC Division of Water Quality, Planning Branch
> > Dept. of Environment and Natural Resources
> > 1617 Mail Service Center Fax: (919)
715-5637
> > Raleigh Work: (919)
733-5083 ext. 570
> > NC Conference
2of3 2/12/032:47PM

[Fwd: Star Inspection]
Subject: [Fwd: Star Inspection]
Date: Wed, 12 Feb 2003 12:50:44 -0500
From: Deborah Gore <[e-mail]>
Organization: NC DENR DWQ
• To: Susan A Wilson <[e-mail]>
Sorry, I didn't even look at the address book. Just assumed you were
THE Susan Wilson, so no problem.
Deborah Gore
Environmental Engineer
Division of Water Quality
Water Quality Section
Pretreatment Unit
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
telephone: [phone] x593
facsimile: [phone]
http://h2o.enr.state.nc.us/Pretreat/index.html
Subject: Star Inspection
Date: Wed, 12 Feb 2003 09:11:00 -0500
From: Deborah Gore <[e-mail]>
Organization: NC DENR DWQ
To: Susan Wilson <[e-mail]>
Susan,
Dave asked me to contact you and let you know that the EPA has
contracted an inspector to conduct pretreatment compliance inspections
at POTWs that receive textile waste. They picked Star and Red Springs.
We will be meeting at Star tomorrow morning at 9:00. I knew that they
were coming, but the date was only set yesterday. I'm sorry that I
didn't think to let you know about this sooner. I plan to drive my own
car and leave from Cary because I have to get my girls to school, but
if you are interested in going, maybe we can meet at my house? If you
don't think it will be a good use of your time, I will let you know the
outcome. The inspectors name is Jerry Whittum. He worked with the
State about 10 years ago, I don't remember exactly in what capacity. He
plans to review the files, tour the treatment plant and visit the two
remaining SIUs in Star: Clayson and Pine Hosiery.
The date for the Red Springs inspection has not yet been set. It will
probably be in early March.
Let me know if you are interested in going to Star or Red Springs.
Deborah Gore
Environmental Engineer
Division of Water Quality
Water Quality Section
Pretreatment Unit
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
telephone: [phone] x593
facsimile: [phone]
1 of 2 2/ 12/03 2:47 PM

[Fwd: Star Inspection]
http://h2o.enr.state.nc.us/Pretreat/index.html
2 of 2 2/12/03 2:47 PM

[Fwd: [Fwd: from connie allred/rocky river]]
Subject: [Fwd: [Fwd: from connie allred/rocky river]]
Date: Wed, 12 Feb 2003 09:54:50 -0500
From: Dave Goodrich <[e-mail]>
To: Susan A Wilson <[e-mail]>
Please respond to Alan (it's Pittsboro Day, apparently). Thanks.
Subject: [Fwd: from connie allred/rocky river]
Date: Wed, 12 Feb 2003 08:43:47 -0500
From: Alan Clark <[e-mail]>
To: Michelle Woolfolk <[e-mail]>,
Dave Goodrich <[e-mail]>
Hi folks. I've received an inquiry and concern regarding Pittsboro's
WWTP expansion. Could the two of you briefly update on the what's
happening with Pittsboro and whether they're really contemplating a
discharge to the Rocky River.
Thanks, Alan
Subject: from connie allred/rocky river
Date: Wed, 12 Feb 2003 01:49:39 GMT
From: [e-mail] (Herb &Connie Allred)
To: [e-mail]
Hi Alan,
Hope you are well. As you may already know, The Town of Pittsboro is
planning to enlarge their waste water treatment plant. Along with the
expansion, they are also contemplating a new discharge site into the
lower Rocky River. How can this be seriously considered? Aside from
the fact that this area is Federally Designated Habitat for the Cape
Fear Shiner, there was also modeling done when Siler City was
expanding their WWTP that showed that the Rocky River could not
tolerate any additional nitrogen. I believe that the modeling
predicted, based on the amount of nitrogen released under Siler City's
current NPDES permit, that there would be dissolved oxygen sags in the
downstream Rocky River. This modeling was also based on the erroneous
assumption that Siler City would not violate their NPDES permit.
These are just a few of the obvious reasons why an additional point
source discharge of millions of gallons into the Rocky is an absurd
idea. I would like to review all drafts of the pending EIS. Who
should I contact for access to those drafts? Thanks for your help.
Connie Allred
Alan Clark <[e-mail]>
Environmental Supervisor
NC Division of Water Quality, Planning Branch
Dept. of Environment and Natural Resources
1 of 2 2/ 12/03 2:48 PM

Michael F. Easley, Governor
7 William G. Ross Jr., Secretary
QG North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
January 13, 2003
MEMORANDUM
TO: Melba McGee
Department of Environment and Natural Resources
FROM: J. Todd Kennedy
Division of Water Quality, Water Quality Section
SUBJECT: Scoping for Pittsboro WWTP Expansion (#03-E-0183)
The Division of Water Quality (Division) has reviewed the subject document. The Water Quality Section
works to maintain or restore and improve aquatic environments for protection of existing or best intended
uses of surface waters. Those uses include drinking water, recreation, agricultural and other purposes,
- and the protection and maintenance of aquatic life.
The Division will be the lead agency in coordinating preparation of the Environmental Assessment (EA)
for this project under the NC Environmental Policy Act (SEPA). The Division is responsible for the
scope, objectivity, content and accuracy of the environmental document.
The NC Department of Administration's guidelines should be consulted for EA preparation. In addition,
the Division submits the following comments:
• A full review of alternatives to discharge expansion will be required. The EA should discuss the
existing system and need for the expansion, and provide proper justification for an increase in
flow. Flow justification should cover a 20-year period and correspond with the master plan. If the
expansion is phased, the corresponding flow for each phase must be justified. The Division's
guidance for preparing the Engineering Alternatives Analysis can be found on the web at
http://h2o.enr.state.nc.us/NPDES/documents.html.
• The applicant must submit a speculative waste limits (SWL) request to the Division prior to
submittal of the EA. Please plan to allow adequate time for this evaluation. The Division's more
SWL
response should be attached to the EA as an appendix. Contact the NPDES Unit for m
information at 919.733.5083 x517 or visit the Unit's website:
http://h2o.enr.state.nc.usINPDES/NPDESweb.html.
• Identify waters of the state at the project site and within the project service area indicating name,
location, classification, and use support rating. Information on use support is available in
Basinwide Water Quality Plans(http://h2o.enr.state.nc.us/basinwide/). Stream classifications are
available through BIMS at the Classification and Standards Unit's website
(http:llh2o.enr.state.nc.us/csu/). Discuss and quantify wetland and stream impacts.
• Secondary and cumulative impacts associated with growth and development may result from this
project. Impacts at the project site and within the service area should be discussed in proportion
AVA
Cu
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] stomer Service DER
NCNC800 623.7748

. Pittsboro WWTP
Page 2
to their significance. Mitigation measures should be employed to avoid significant impacts to the
surrounding environment.
What are the existing and proposed land uses within the service area? Discuss land use,
population, development density and pattern, zoning and zoning densities, growth trends and
growth projections within the project service area. Describe potential land use changes and
impacts from induced growth effects of the project. Provide maps of service areas, discuss where
the anticipated growth is likely to be located and the development types that are expected, and
identify any associated infrastructure projects.
The EA should describe specific ordinances and regulations in appropriate detail and discuss how
and to what degree they mitigate any secondary impacts to water resources. Adequate mitigation
of significant impacts must be provided to support a Finding of No Significant Impact. Note that
compliance with existing state regulations may not equate to insignificant impacts. In the event
that existing state and local programs do not provide adequate mitigation, additional local
protection may need to be considered at both the city/town and county level. Emphasis should be
placed on actual implementation of mitigation measures.
Secondary Impacts/Stormwater
Maintaining predevelopment hydrologic functions is an important goal in watershed
development. Planning design that reduces the creation of impervious area, provides for pervious
green infrastructure, and maintains natural detention and retention functions should be
encouraged.
Consider modifying existing development codes to allow clustered developments with open space
to provide developers design flexibility to reduce site impacts. Low impact development methods
should be encouraged.
When development in a watershed exceeds 10% to 15% impervious surface coverage, a lack of
adequate stormwater control will likely lead to downstream degradation of stream channels and
water quality. Appropriate measures to reduce pollution, maintain groundwater recharge and
minimize stream channel erosion must be implemented.
For new development, stormwater controls should protect against stream damage due to increases
in volume, velocity and peak rates of stormwater. Small, frequent storms are responsible for the
majority of channel erosion in streams. And smaller storms also account for the majority of
rainfall events generating runoff. As imperviousness in the watershed increases, the frequency of
bankfull and mid-bankfull flows associated with channel formation typically increases in
response. Therefore, extended detention of the one-year, 24-hour storm event should be
considered to adequately protect channels. In addition, stormwater runoff generated by
development should be treated to decrease pollutant loading into nearby water bodies.
Alternative control measures may be appropriate given that they reduce the frequency, magnitude
and duration of post -development bankfull flow conditions and protect downstream channels
from erosion. Note that controls based solely on large storm events (e.g., 10-yr and 25-yr) may
provide overbank flood protection but generally fail to protect water quality and stream integrity.
Secondary Impacts/Buffers
Discuss measures designed to protect critical ecosystem functions of riparian buffers. Vegetated
buffers are a typical component required for comprehensive protection of streams. Widths of 50

. Pittsboro WWTP
Page 3
feet for intermittent streams and 100 feet for perennial streams are recommended. A significant
portion of the buffer adjacent to the streambank should be undisturbed, natural vegetation.
Altemative measures suitable for this area may be considered given they provide a similar level
of protection.
• Please include copies of all agency correspondence in the Appendix.
Direct, indirect and cumulative impacts at the project site and within the service area should be discussed
in proportion to their significance. Mitigation must be employed to avoid significant impacts to the
surrounding environment and to support a Finding of No Significant Impact. Emphasis should be placed
on actual implementation of mitigation measures.
Once the applicant has completed a draft EA, one copy of the document should be submitted directly to
the Division for a completeness review. This completeness review takes a minimum of two to three
weeks and may result in the document being returned to the applicant for necessary revisions. Next, the
document will be reviewed by relevant agencies within the Department of Environment and Natural
Resources (DENR), the NC Wildlife Resources Commission, and applicable federal agencies. Any issues
identified during this review will need to be resolved and the EA will need to be amended to address the
issues before further Clearinghouse review can proceed. If impacts cannot be reduced or mitigated to a
level of insignificance, an EIS (Environmental Impact Statement) will be required.
Additional guidance regarding SEPA document preparation for Division projects can be found at
http://h2o.enr.state.nc.us/sepa/index.htm. I may be contacted at 919.733.5083 x514.

DIEHL & PHILLIPS, P.A.
CONSULTING ENGINEERS
219 East Chatham Street
Cary, North Carolina 27511
Telephone [phone] — Fax [phone]
January 10, 2003
Ms. Susan Wilson
NPDES Permit Section
DWQ, NCDENR
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: USGS Stream Flow Estimates
Speculative Waste Load Allocations
Town of Pittsboro
Dear Ms. Wilson:
WILLIAM C. DIEHL, P.E.
JOHN F. PHILLIPS, P.E.
ALAN R. KEITH, P.E.
JAN 13 2003
r„ t
To assist DWQ in formulating the speculative waste load allocations requested in Mayor May's
Ietter of December 19, 2002, please find enclosed stream flow estimates for the two sites (one on
Rocky River, one on Deep River). The estimates were prepared by Mr. Curtis Weaver of USGS,
and include the S7Q10, W7Q 10, annual 30Q2, and annual 7Q2 flow estimates.
Please call if you have any questions or comments.
Yours very truly,
Diehl & Phillips, P.A.
John F. Phillips, P.E.
Enclosure
Cc: Mr. Hugh Montgomery, Town Manager w/enc.

United States Department of the Interior
U.S. GEOLOGICAL SURVEY
3916 Sunset Ridge Road
Raleigh, North Carolina 27607
January 3, 2003
Mr. John F. Phillips, P.E.
Diehl & Phillips, P.A.
219 East Chatham Street
Cary, North Carolina 27511
Dear Mr. Phillips:
In response to your request for low -flow data, the U.S. Geological Survey (USGS) does not have site -spe-
cific, low -flow discharge data for Rocky River at SR 1953 at Ashbury, NC (station id 0210189369, drainage
area 234 mi2) or Deep River below Rocky River near Ashbury, NC (station id 0210194905, drainage area
1,425 mi2). The low -flow characteristics that are provided on the attached sheets have been computed by
correlating the runoff characteristics of nearby continuous- and partial -record sites in vicinity of the request
sites. Please note that the flow estimates do not account for the presence of any diversions or regulation,
present or future, which may occur upstream of the request sites.
For the site on Rocky River, low -flow characteristics determined at a downstream partial -record site having
a drainage area of 237 mi2 were applied directly to the request site. A profile presented for the Rocky River
in the recently published report; "Low -flow characteristics and discharge profiles for selected streams in
the Cape Fear River basin, North Carolina" (Weaver, 2001) allows for the estimation of low -flow discharges
at the request site. Based on the profile, low -flow characteristics at the partial -record site were applied
directly to the request site (based on minor differences in drainage areas).
Similarly for the site on Deep River, low -flow characteristics determined at a downstream continuous -
record site having a drainage area of 1,434 mil were applied directly to the request site. A profile presented
for the Deep River in the published report, "Low -flow characteristics and discharge profiles for Deep River
in the Cape Fear River Basin, North Carolina" (Weaver, 1997) allows for the estimation of low -flow dis-
charges at the request site. Based on the profile, low -flow characteristics at the continuous -record site were
applied directly to the request site (again, based on minor differences in drainage areas).
A charge for accessing and processing information has been assessed to partially offset these costs. Your
requested data and an invoice covering processing costs for these data are enclosed. Please forward the
original bill with your check to the U.S. Geological Survey, 12201 Sunrise Valley Drive, MS 271, Reston,
Virginia 20192.
These data are preliminary and subject to revision pending approval for publication by the Director of the
U.S. Geological Survey, and are made available through our cooperative program of water -resources inves-
tigations with the North Carolina Department of Environment and Natural Resources.
If you have any questions regarding this information, please contact us at [phone].
Enclosures
Sincerely,
('41/-1 t&twe,-
Curtis Weaver
Hydrologist
[phone] • FAX [phone]

SUMMARY OF LOW -FLOW ESTIMATES IN RESPONSE TO REOUEST
REQUEST NO: 91619 SITE NO: 01 DATE: 01/03/2003
SOURCE: Consultant ACTION: Existing
STATION NUMBER: 0210189369 STATION TYPE: Ungaged (20)
STATION NAME: Rocky River at SR 1953 at Ashbury, NC
LOCATION: At Secondary Road 1953, and 1.0 mile north of Ashbury
LATITUDE: 35°37'25" LONGITUDE: 79° 12'00"
QUANDRANGLE NAME AND NUMBER: Colon 1E-22-SW1
COUNTY CODE: Chatham 10371 STATE CODE: NC f371 DISTRICT CODE: NC [371
HYDROLOGIC UNIT CODE: 03030003 ENR BASIN CODE: 03-06-12
DRAINAGE AREA: 234. mil
Flow statistics as follows:
AVERAGE FLOW: Estimated using 1.0 ft3/s/mi2 234. ft3/s see note f B l
ANNUAL 7Q10 MINIMUM FLOW: ft3/s/mi2 1-4 ft3/s see note [ B ]
ANNUAL 30Q2 MINIMUM FLOW: ft3/s/mi2 9-8 ft3/s see note [ B 1
WINTER 7Q10 MINIMUM FLOW: ft3/s/mi2 5.5 ft3/s see note L B 1
ANNUAL 7Q2 MINIMUM FLOW: ft3/s/mi2 5.2 ft3/s see note C B 1
NOTES:
[A] Estimate is based on records collected at dr near the request site.
[B] Estimate is based entirely on runoff characteristics observed at nearby streams.
[C] Estimate based on procedures given in USGS Water Supply Paper 2403 "Low -flow Characteristics
of Streams in North Carolina" (Giese and Mason, 1993).
[D] Estimate based on procedures given in USGS Water Supply Paper 2403 and in conjunction with
streamflow records collected at or near the request site.
[E] See remarks.
These data are considered provisional and subject to revision pending approval by the Director, USGS.
REMARKS:
• Low -flow estimates based on downstream partial -record site (Sta. 02101946, drainage area 237 mi2) where
low -flow characteristics have been determined (ref: Cape Fear low -flow report, WRIR 01-4094, Table 8).
Due to minor difference in drainage areas, values at Sta. 02101946 applied directly to request site.
• Requested by Mr. John F. Phillips, Diehl & Phillips, P.A.
ENTERED BY: JCW FEE CHARGED: $ 150

SUMMARY OF LOW -FLOW ESTIMATES IN RESPONSE TO REQUEST
REQUEST NO: 91619 SITE NO: 02 DATE: 01/03/2003
SOURCE: Consultant ACTION: New
STATION NUMBER: 0210194905 STATION TYPE: Unpaged (20)
STATION NAME: Deep River below Rocky River near Ashbury, NC
LOCATION: Immediately downstream of Rocky River, and approx. 3 miles east-northeast of Ashbury
LATITUDE: 35°37'04" ✓ LONGITUDE: 79°08'59" f
QUANDRANGLE NAME AND NUMBER: Colon TE-22-SW1
COUNTY CODE: Chatham 10371 STATE CODE: NC T371 DISTRICT CODE: NC 1371
HYDROLOGIC UNIT CODE: 03030003 ENR BASIN CODE: 03-06-11
DRAINAGE AREA: 1,425. mi2
Flow statistics as follows:
AVERAGE FLOW: Estimated using 1.0 f /s/mi2 1425. ft3/s see note [B.]ANNUAL 7Q10 MINIMUM FLOW: ft3/s/mi2 24. ft3/s see note [ B j
ANNUAL 30Q2 MINIMUM FLOW: f 3/s/mi2 113. ft3/s see note [_13_]
WINTER 7Q10 MINIMUM FLOW: ft3/s/mi2 45. __ ft3/s see note [ B ]
ANNUAL 7Q2 MINIMUM FLOW: ft3/s/mi2 71. ft3/s see note LL3 J
NOTES:
p- v,7 A,,i�cs
f ItdM
CoriF LL tJcn.
[A] Estimate is based on records collected at or near the request site.
[B] Estimate is based entirely on runoff characteristics observed at nearby streams.
[C] Estimate based on procedures given in USGS Water Supply Paper 2403 "Low -flow Characteristics
of Streams in North Carolina" (Giese and Mason, 1993).
[D] Estimate based on procedures given in USGS Water Supply Paper 2403 and in conjunction with
streamflow records collected at or near the request site.
[E] See remarks.
These data are considered provisional and subject to revision pending approval by the Director, USGS.
REMARKS:
•
• Low -flow estimates based on downstream continuous -record site (Sta. 02102000, drainage area 1,434 mi2)
where low -flow characteristics have been determined (ref: Cape Fear low -flow report, WRIR 01-4094,
Table 7). Due to minor difference in drainage areas, values at Sta. 02102000 applied directly to request site.
• Requested by Mr. John F. Phillips, Diehl & Phillips, P.A.
ENTERED BY: JCW FEE CHARGED: $ 150

TOWN OF
NANCY R. MAY
Mayor
HUGH R. MONTGOMERY
Town Manager
PAUL S. MESSICK, JR.
Town Attorney
P.O. Box 759 — 635 East Street
PITrSBORO, N.C. 27312
December 19t, 2002
Ms. Susan Wilson
NPDES Permit Section
DWQ, NCDENR
1617 Mail Service Center
Raleigh, N. C. 27699-1617
RE: Town of Pittsboro
Request for Speculative Waste Load Allocation
Dear Ms. Wilson:
BOARD OF COMMISIONERS
GENE. BROOKS
MAX G. COTTEN
BURNICE N. GRIFFIN, JR.
CHRIS WALKER
CLINTON E. BRYAN, JR.
TELEPHONE
[phone]
FAX [phone]
The Town of Pittsboro is beginning the environmental document process necessary to explore possible
NPDES permit locations along either the lower Rocky River, or the Deep River near its confluence with the
Rocky River. To assist in this process the Town requests speculative waste load allocations be prepared for
the two sites indicated on the enclosed map.
At this point the Town has not yet determined the size of the proposed discharge, although we believe it
will be between 2.0 and 4.0 MGD. For the purposes of the waste load allocation, please use 4.0 MGD.
We have requested stream flow data from USGS for the two sites, and will forward that to you when we
receive it. Please call Mr. John Phillips, PE at Diehl & Phillips [phone], or Mr. Hugh Montgomery,
Town Manager, [phone], ex. 22 if you have any questions regarding this request. If there is any
charges associated the preparation of the WLA's, please let Mr. Montgomery know.
Thank you in advance for your considerations and continued assistance in this matter.
Sincerely,
ancy R. May
Mayor
CC. Town of Pittsboro Board of Commissioners
Mr. John Phillips, PE
3 13 2002
CHARTERED 1787

Ottt -
DIEHL & PHILLIPS, P.A.
_n/c3
gasat/k-
CONSULTING ENGINEERS
219 East Chatham Street
Cary, North Carolina 27511
Telephone [phone] • Fax [phone]
December 18, 2002
Ms. Chrys Baggett, Director
State Clearinghouse
N.C. Department of Administration
1302 Mail Service Center
Raleigh, NC 27699-1302
Re: Request for Environmental Document Scoping Assistance
Proposed NPDES permit
Town of Pittsboro
Dear Ms. Baggett:
WILLIAM C. DIEHL, P.E.
JOHN F. PHILLIPS, P.E.
ALAN R. KEITH, P.E.
The Town of Pittsboro is evaluating its alternatives for an increase in its wastewater
treatment and disposal capabilities. The Town is beginning to experience the growth and
development issues that have occurred in this region of the state over the last fifteen to
twenty years, and wishes to be proactive in determining its utility system's expansion
capabilities and limitations. Based on the Town's knowledge of the limitations of
Robeson Creek, their current wastewater discharge receiver, it has been decided to
investigate a potential discharge into the lower Rocky River or the Deep River, near its
confluence with the Rocky River. The first step in this process will be the preparation of
an environmental document, as required under 15 NCAC 1C. The environmental
document will refine the location of the potential discharge point; at this time we believe
it will either be in the Rocky River, between NCSR 1953 and the confluence with the
Deep River, or in the Deep River between the confluence with the Rocky River and a
point one mile east of the confluence. The volume of the requested discharge will
probably be in the range of 2.0 to 4.0 millions of gallons per day.
We are writing on behalf of the Town of Pittsboro to request your assistance in notifying
all of the agencies that will review the environmental document of the Town's intentions
to pursue this additional discharge permit. We are requesting input from all interested
agencies to help us formulate the scope of the environmental document. After receipt of
the written comments, suggestions, and concerns of each agency, we propose to meet
with those commenting to insure the draft environmental document addresses their
specific points of interest.

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Ms. Chrys Baggett
Page 2 of 2
December 18, 2002
Attached is -a map showing the general Iocation of the proposed discharge point. Please
call if you have any questions.
Cc: Mr. Hugh Montgomery, Town Manager
Yours Very Truly,
Diehl & PhiIlips, P.A.
John F. PhiIlips, P.B.

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•
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512 N. Salisbury St. Raleigh NC 27604 Phone [phone]

•
CAPE FEAR RIVER BASIN
Name of Stream
Subbasin Stream Index Number Map Number Class
Rock Creek CPF02 16-21-1 D21NE1 C NSW
Rock Creek CPF17 18-81-4 K26NW9 C Sw
Rock Fish Creek (New Kirk Pond) CPF19 18-74-29 H26SE4 C Sw
Rock Fish Creek (New Kirk Pond) CPF22 18-74-29 H26SE4 C Sw
Rockfish Creek CPF15 18-31-(1) G21NE7 C
Rockfish Creek CPF15 18-31-(12) G22SW7 B
Rockfish Creek CPF15 18-31-(15) H22NW2 C
Rockfish Creek CPF15 18-31-(23) H23NW2 C
Rockfish Creek [(Upchurches Pond, Old Brower CPF15 18-31-(18) H23NW2 B
Mill Pond (Number Two Lake) ]
Rocky Branch CPF02 16-11-12 C2ONW6 C NSW
Rocky Branch CPF11 17-41-1 E22SW1 C
Rocky Branch CPF11 17-44-(1) E22NW9 C
Rocky Branch CPF11 17-44-(2) E22NW9 WS-IV
Rocky Branch CPF19 18-68-6-1 I25NE6 C Sw
Rocky Ford Branch CPF05 16-41-6-4-(1) D23SW8 WS-IV NSW
Rocky Ford Branch CPF05 16-41-6-4-(2) D23SW8 WS-IV NSW CA
Rocky Marsh Creek (Best Pond) CPF19 18-68-1-15 H25NE7 C Sw
Rocky River CPF12 17-43-(1) D2OSE5 WS-III
Rocky River CPF12 17-43-(7.5) D21SW7 WS-III CA
Rocky River CPF11 17-43-(8) D21SW8 C
Rocky
River CPF12 17-43-(8) D21SW8 C
Rocky Run Creek CPF13 18-20-16 F23SW4 C
Rollins Branch CPF17 18-68-22-1-2-3 J26NW8 C Sw
Rollins Branch CPF20 18-68-22-1-2-3 J26NW8 C Sw
Rooty Branch CPF13 18-20-14 F23SW1 C
Rooty Branch CPF22 18-74-19-12 G27SW4 C Sw
Rose Creek (Apple Pond) CPF01 16-8 C2ONW3 C NSW
Roundabout Branch CPF14 18-23-16-6 F22SW7 WS-III
Rowan Creek CPF20 18-68-13 125SE9 C Sw
Rowans Branch (Chestnut Pond) CPF19 18-68-2-8 H25NE3 C Sw
Rowell Branch CPF17 18-77-1-1-1 J26SE8 C Sw
Royal Mill Branch CPF19 18-68-1-10-4 G25SE7 C Sw
Run Branch CPF13 18-20-6-2-1 F22SW2 C
Run Branch CPF21 18-74-6-2 G27NW5 C Sw
Russells Creek CPF17 18-81-5 K26NW9 C Sw
Ryan Creek CPF02 16-11-14-2-3 C19SE8 C NSW
Salt Marsh Ditch CPF20 18-68-22-1-2-1-1 J25NE6 C Sw
Salters Lake CPF16 18-44-4 I24NW6 C
Sand Hill Creek CPF23 18-74-42-1 I27SE8 C Sw
Sand Hill Creek CPF17 18-83 K27SW1 C Sw
Sandy Branch CPF12 17-43-16-1 E21NW9 C
Sandy Creek CPF05 16-41-1-11 C23SW8 C NSW
Sandy Creek CPF09 17-16-(1) D2ONW9 WS-III
Sandy Creek CPF09 17-16-(3.5) E2ONW2 WS-III CA
Sandy Creek CPF09 17-16-(4) E2ONW2 C
Sandy Creek CPF18 18-68-12-6 H24NW3 C Sw
Sandy Run CPF09 17-18-1 E2ONW6 C
Sandy Run CPF21 18-74-6.5 G27NW9 C Sw
Sandy Run CPF21 18-74-14 G27SE1 C Sw
Sandy Run Swamp CPF23 18-74-33-2 I28NE7 C Sw
Sawyer Branch CPF21 18-74-13-1 G27SE3 C Sw
Sawyer Creek CPF22 18-74-29-5 I27NW4 C Sw
Schoolhouse Branch CPF13 18-20-13-8 F22SE3 C
Pag 24 of 30
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