NC0020354_Speculative Limits_20130220

NPDES DOCU BENT 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
Instream Assessment (67b)
Speculative Limits \
Environmental Assessment (EA)
Document Date:
February 20, 2013
This document is printed on reuse paper - ignore any
content on the re -Terse side

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North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P. E. John E. Skvarla, III
Governor Director Secretary
February 20, 2013
Mayor Randolph Voller
Town of Pittsboro
Pa Box 759
635 East Street
Pittsboro, North Carolina 27312
Subject: Town of Pittsboro /Review of Robeson Creek Discharge
NPDES Permit NC0020354
Dear Mayor Voller:
It was a pleasure meeting with you and Bryan Gruesbeck on January 22, 2013 to discuss potential
NPDES wastewater discharge alternatives. This letter addresses the issues discussed in that meeting and
in your letter to me dated December 10, 2012. Your current permit provides for a discharge (up to 0.75
MGD) to Robeson Creek, with a future expansion (up to 2.47 MGD) to the Haw River, for a total
permitted discharge of 3.22 MGD. Due in part to the high capital costs for a discharge to the Haw River,
you requested that Division of Water Quality (DWQ) evaluate the possibility of additional flow being
sent to Robeson Creek as an interim wastewater solution. Based on further evaluation by DWQ staff, I
offer the following thoughts for your consideration.
Expanding Flow to Robeson Creek Beyond 0,75 MGD.
The limiting factor for additional wastewater flow to Robeson Creek has been the EPA -approved 2004
Total Phosphorus (TP) TMDL, which results in a fixed TP limit of 322 pounds TP/summer season to
Robeson Creek. The entire TMDL point source load was allocated to the Pittsboro WWTP. In order to
comply with this TP load limit, Pittsboro would need to achieve the following summer average TP
effluent concentrations at the specified flows: 0.75 MGD (0.24 mg/1 TP), 1.0 MGD (0.18 mg/1 TP), 1.5
MGD (0.12 mg/1 TP), 2.0 MGD (0.09 mg/1 TP), 2.5 MGD (0.07 mg/1 TP), 3.22 MGD (0.05 mg/1 TP).
Significant progress has been made over the last decade in phosphorus removal mechanisms, to the point
where some facilities are meeting limits less than 0.1 mg/1 TP. However, these require specialized
attention and specialized TP removal processes, and can be costly.
In light of the noted advances in TP reduction, DWQ would be willing to reconsider additional flow to
Robeson Creek. As a first step, it is recommended that you seek input from your consulting engineers
regarding what additional flow you might propose to discharge to Robeson Creek, based on level of TP
treatment required and cost to achieve those levels. Then you might want to schedule another meeting
with DWQ for further discussion. Additional steps would include a request to the NPDES Permit Unit
1617 Mail Service Center, Raleigh, Noilh Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.ncwateraualitv.orq
An Equal OpporlunllylAffirmativeAden Employer
NYonithCarohna
/Vaturallij
7013

Mayor Voller
February 20, 2013
Page 2 of 2
for speculative limits for the proposed discharge volume to Robeson Creek, to determine whether there
will be any changes to other permit limits (e.g., BOD, ammonia). It might also be advisable to discuss TP
treatment design with DWQ's Infrastructure Finance Section/Design Management Unit, as you would
ultimately need to secure an Authorization to Construct (ATC) permit and provide engineering designs
for treating TP to low levels. Finally, a reminder that both Robeson Creek and Haw River discharge to
Jordan Lake, for which the Jordan Lake TMDL sets both Total Nitrogen and Total Phosphorus mass
limits based on the total discharge from Pittsboro WWTP.
Potential State gnviconmental Policy Act (SEPA) Actions.
The Town of Pittsboro received a SEPA Environmental Impact Statement (EIS), Record of Decision, on
March 19, 2010, for the wastewater expansion to Haw River. If the Town proposes to increase the
wastewater discharge to Robeson Creek, this additional flow must be subtracted from the volume allotted
to the Haw River discharge, so the total permitted flow remains at 3.22 MGD. If the requested flow
expansion to Robeson Creek exceeds 0.5 MGD, then the SEPA EIS must be reopened.
Robeson creek jnstream Reads@ssmcint.
Robeson Creek was initially impaired for chlorophyll -a, which was addressed by the development of the
Robeson Creek TP TMDL. The creek is still listed as impaired on the 2012 303(d) list for aquatic life.
Significant work has been undertaken to improve water quality conditions. DWQ will attempt to re-
evaluate the status of the benthic impairment with additional field sampling this summer.
I hope this information assists you with your future wastewater planning needs. If you have any
questions, please contact me or the following DWQ staff for specific technical questions:
NPDES Permitting/Speculative Limits: Tom Belnick, 919-807-6390
SEPA Actions: Jeff Manning, 919-807-6415
ATC Permitting/Design Approval: Seth Robertson, 919-707-9175
Robeson Creek Impairment Rating: Kathy Stecker, 919-807-6422
Sincerely,
aie-4/4,6/
Charles Wakild, P.E.
Cc: Bryan Gruesbeck, Pittsboro Town Manager
ECopy: Ted Bush, Matt Matthews, Kathy Stecker, Seth Robertson, Jeff Manning
Danny Smith, Eric Fleck, Tom Belnick, Jeff Poupart

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Town of Pittsboro--Robeson Creek Discharge
DENR-DWQ ARCHDALE 9TH FLOOR CONF ROOM 917
Tue 1/22/2013 2:30 PM
Tue 1/22/2013 4:00 PM
Tentative
Recurrence: (none)
Meeting Status:
Organizer: Wakild, Chuck
Required Attendees: , Matthews, Matt; Poupart, Jeff; Belnick, Tom; Stecker, Kathy f?rAila
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2012 North Carolina 303(d) List -Category 5
Cape Fear River Basin
> U •dumb ;r
Name
10-digit Watershed
0303000207
Length or Area:
Roberson Creek -Haw River
Units Classification
�'gor"y
Category Rating Use
Reason for Rating
Parameter
Year
> 16-(37.5)b
Haw River (B. Everett
Jordan Lake below
normal pool elevatio
Robeson Creek Arm of Jordan Reservoir
47.0
FW Acres
WS-IV,B;NSW,CA 5
5 Impaired
5 Impaired
Aquatic Life
Aquatic Life
Standard Violation
Standard Violation
Turbidity
High pH
2006
2006
> 16-38-(3)a
Robeson Creek
From a point 0.7 mile downstream of Chatham County SR 2159 to
Pittsboro Lake
0.9 FW Miles WS-IV;NSW
Impaired Aquatic Life
Fair Bioclassification
Ecological/biological Integrity Benthos
1998
5
> 16-38-(3)c
Robeson Creek
From Pittsboro Lake to UT across from SR 1951
2.4 FW Miles WS-IV;NSW
5 Impaired Aquatic Life
Fair Bioclassification
Ecological/biological Integrity Benthos
1998
5
> 16-38-4
Turkey Creek
From source to Robeson Creek
4.1 FW Miles WS-IV;NSW
S Impaired
Aquatic Life
Fair Bioclassification
Ecological/biological Integrity Benthos
2012
5
12-digit Subwatershed
030300020704
Stinking Creek -Haw Rive
> 16-(37.3)
HAW RIVER
From a point 0.5 mile downstream of US Hwy 64 to approximately 1.0 mil 53.2
below US Hwy 64
FW Acres WS-IV;NSW,CA 5
5 Impaired Aquatic Life
5 Impaired Aquatic Life
Standard Violation
Standard Violation
High pH
Turbidity
2006
2006
Cape Fear River Basin
Cape Fear River Basin
> 17-(4)a
8-digit Subbasin
10-digit Watershed
12-digit Subwatershed
DEEP RIVER
03030003
0303000301
030300030104
Deep River
Headwaters Deep River
Bull Run -Deep Rive
From dam at Oakdale Cotton Mills, Inc, to SR 1113
2.0 FW Miles W5-IV;CA:* 5
5 Impaired Aquatic Life
Standard Violation
Low Dissolved Oxygen
2010
12-digit Subwatershed
030300030110
Hasketts Creek -Deep Rive
Friday, August 24, 2012
Approved by EPA August 10, 2012
Page 12 of 170

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Primit hie Norozossy
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
Mayor Randolph Voiler
Town of Pittsboro
PO Box 759
635 Bast Street
Pittsboro, NC 27312
Dear Mayor Voller,
It was a pleasure speaking with you earlier today about Pittsboro's request to modify the duel -
discharge requirement in the Town's current NPDES wastewater discharge permit. The
Division of Water Quality is certainly open to reviewing alternatives with you and, as we agreed,
a meeting in January is probably the best way to begin some initial discussion of the water
quality issues and identify a path forward.
We will contact Mr. Gruesbeck for some possible meeting dates and plan to meet here at the
Archdale Building in Raleigh. We look forward to working with you and the Town along with
other interested parties to find the best solution possible.
December 20, 2012
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Please call me if you have questions or wish to discuss this further.
Sincerely,
Chuck Wakild
Cc: Bryan Gruesbeck, Pittsboro Town Manager
1617 Mall Service Center, Raleigh, North Carolina 27699.1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet www.ncwatercualitv.orq
An Equal Opportunity 1 Affirmative Action Employer
None
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From: Stecker, Kathy
Sent: Thursday, January 24, 2013 10:11 AM
To: Belnick, Tom
Subject: RE: follow-up info for Pittsboro
Eric has agreed to go back this year for an update.
Will keep you posted.
From: Stecker, Kathy
Sent: Wednesday, January 23, 2013 10:11 AM
To: Belnick, Tom
Subject: RE: follow-up info for Pittsboro
The biologists typically would not go back to impaired sites in urbanized areas, unless we knew of activities that might
have improved the conditions.
I will ask Eric to try to schedule an update, because there has been some work in that watershed.
From: Belnick, Tom
Sent: Wednesday, January 23, 2013 9:36 AM
To: Stecker, Kathy
Subject: RE: follow-up info for Pittsboro
Thanks Kathy. Just one question on Item 3- the biologically impaired sections in Robeson Creek for benthics was
established in 1998 (based on 303d list). Have we done updated benthic sampling since then?
Tom Belnick
Supervisor, NPDES Complex Permitting Unit
NCDENR/Division of Water Quality
919-807-6390
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Stecker, Kathy
Sent: Tuesday, January 22, 2013 4:45 PM
To: Belnick, Tom
Cc: Matthews, Matt; Manning, Jeff; Poupart, Jeff; Deamer, Nora
Subject: follow-up info for Pittsboro
1. The TMDL did not include any point sources besides Pittsboro; therefore, there is no additional WLA available
from the TMDL for them to use.
2. As of 2010, the creek's embayment at Jordan was still not meeting the chlorophyll standard (exceeded in 40% of
samples).
3. There are biological impairments in Robeson Creek in Pittsboro. The WWTP is not the only potential cause. The
2005 Cape Fear basin plan says, "The benthic communities were stressed by habitat degradation associated with
runoff from urban areas..."
I think that's all I was supposed to find out. Let me know if there are questions or you need more info.
1

Kathy Steckel'
NCDWQ
919-807-6422
NOTICE: Emails sent to and from this account are subject to Public Records Law and may be disclosed to third parties.
2

69'1b"'° WCOOZO3SY
RANDOLPH VOLLER
Mayor
WIWAM G. TERRY
Town Manager
PAUL MESSICK, JR.
Town Attorney
P.O. BOX 759, 635 EAST ST.
PIITSBORO, NC 27312
December 18, 2012
TOWN OF
1jJjWQ inv cOK,,r;IL.
,Holt /;*i ¢o 00r046,.�..G�
Secretary Dee Freeman
NC Department of Environment and Natural Resources
512 North Salisbury Street
Raleigh, North Carolina, 27699-1601
Subject: Request to Review the Robeson Creek Discharge for the Town of Pittsboro, NC
Dear Secretary Freeman:
It was a pleasure chatting with you yesterday. Attached you will find a letter the Town of Pittsboro has
sent to DENR regarding the discharge permit to Robeson Creek along with letters from the Robeson
Creek Watershed Council (RCWC) and the Haw River Assembly on the aforesaid topic.
For a variety of sensible environmental, ecological, and economic development reasons, I believe that the
State of North Carolina in conjunction with the various local stakeholders should allow the Town of
Pittsboro to eliminate or modify the dual -discharge requirement and increase the Town of
Pittsboro's discharge to Robeson Creek from 0.75 mgd to a level that is sustainable for the
ecological function of Robeson Creek as well the future of Pittsboro and Chatham County.
The Town currently holds a permit to install a pipe along Robeson Creek for many miles to the east and
ultimately discharge an additional 2.47 mgd of effluent into the Haw River.
Besides the extra cost of installing the aforesaid pipe, it is apparent that the installation will potentially
damage the creek buffers and ultimately the discharge at the Haw River may be less preferable than
permitting a greater discharge of effluent at the Town's current location.
It seems logical that a better interim solution would be to allow the Town's updated UW TP plant (we
currently pro uce reuse quality effluent) to discharge a reasonable amount more at its current location,
while other potential solutions and partnerships are evaluated. (I have attached a map from biologist John
Alderman that shows the millions of gallons of effluent already permitted in other watersheds in North
Carolina that are potentially comparable to ours.) I hope you can grant that request.
CHARTERED 1787
BOARD OF COMMISSIONERS
PAMELA BALDWIN
J.A. FARRELL
MICHAEL FIOCCO
BETH TURNER
BETT WILSON-FOLEY
TELEPHONE
919) 542-4621
09
•• v�uSG. nc�VUKI:tS
(114LO We-opetAjL)
Loa, V o

Mr. Dee Freeman, Secretary, NCDENR
Request to Review Robeson Creek Discharge for Pittsboro, NC
date
Page 2 of 2
Thank you very much for considering our request. Occasionally situations arise where good public policy
can align fiscal prudence with the potential for better long term environmental stewardship. This situation
appears to meet that criteria, which has prompted my letter to your office.
I am happy to meet with you in person or chat on the phone regarding our proposal at 949-1274.
Si
Y,
ofra,
V�
R dy Voller, Mayor
Twn of Pittsboro, North Carolina
CC: Mr. Bryan Gruesbeck, Town Manager
Attachments:
(a) Letter to Chuck
(b) Letter from Haw River Assembly
(c) Letter from Robeson Creek Watershed Council
(d) Map from John Alderman
Cekbrating
225 years
Randolph "Randy" S. Voller
MAYO R
TEL [phone]
EMAIL [e-mail]
Town Hall 635 East Street
PO Box 759 Pittsboro, NC 27312
TEL [phone]
FAX [phone]
WEB http://pittsboronc.gov/

TOWN OF
RANDOLPH VOLLER
Mayor
BRYAN L. GRUESBECK
Town Manager
PAUL S. MESSICK, JR.
Town Attomey
P.O. Box 759 — 635 East Street
PITTSBORO, N.C. 27312
December 10, 2012
Mr. Chuck Wakild, Director
Division of Water Quality
NC Department of Environment and Natural Resources
512 North Salisbury Street
Raleigh, North Carolina, 27699-1601
BOARD OF COMMISSIONERS
PAMELA BALDWIN
JAY FARRELL
MICHAEL A. FIOCCO
BETT WILSON FOLEY
BETH TURNER
TELEPHONE
[phone]
FAX [phone]
Subject: Request to Review Robeson -Creek Discha ge for Town of Pittsboro, N
Dear Mr. Wakild:
The Town of Pittsboro, NC is fortunate to see early signs of growth and development return to the heart of
North Carolina's Piedmont region. As expected, we here in Pittsboro are excited about new economic
development opportunities which will add to our rich quality of life and our local business community.
However, we are mindful of our responsibility to preserve, protect, and restore the important environmental
resources of the community that contribute to the rich quality of life afforded in Pittsboro.
We are very grateful to the staff of the North Carolina Department of Environment and Natural Resources
(NCDENR) for working closely with the Town of Pittsboro to process our Environmental Impact Statement
(EIS) for a wastewater treatment plant expansion project that included a dual discharge to Robeson Creek
(0.75 mgd) and the Haw River (2.47 mgd). The Record of Decision (ROD) for the EIS was issued on March
29, 2010, and the Town received approval for the permit renewal and modification on June 2, 2011. Once
again, I want to extend my sincere appreciation to NCDENR staff for taking the time to work with the Town to
achieve this significant milestone for the current and future citizens of Pittsboro.
Since receiving the approved permit renewal and modification on June 2, 2011, the Town has been working to
evaluate options to implement the wastewater treatment upgrade and expansion project with a dual discharge
to Robeson Creek and the Haw River. In August 2012, the Town Board of Commissioners received an
engineering report indicating that the capital cost for the discharge to the Haw River was approximately $5.1
million. Given the scope, scale, and nature of this project and the associated costs, the Town of Pittsboro
respectfully requests an opportunity to meet with you and representatives of your staff to review the dual
discharge requirements defined in the approved permit renewal and modification. Specifically, the Town would
like to discuss the possibility of working with NCDENR and other stakeholders on a watershed -based study to
evaluate the potential to eliminate or modify the dual -discharge requirement and increase the Town of
Pittsboro's discharge to Robeson Creek from 0.75 mgd to a level that is sustainable for the ecological function
of Robeson Creek.
In making this request to collaborate on a watershed -based study, the Town clearly understands that Robeson
Creek was listed as an impaired water body on the 2010 North Carolina 303(d) Impaired Waters List, and that
impairment is related to habitat degradation contributions from both non -point and point sources. However, we
would very much like to work with NCDENR staff and representatives from the Robeson Creek Watershed
Council (RCWC), the Haw River Assembly, the NCSU School of Biological and Agricultural Engineering
CHARTERED 1787

Mr. Chuck Wakild, Director, NCDENR
December 10, 2012
Page 2 of 2
Department, and other stakeholders to identify the optimum combination of point- and non -point source
nutrient reduction measures that can be cost-effectively implemented to mitigate the adverse impacts of
excessive nutrient loading, restore the designated uses of Robeson Creek, and accommodate an increased
discharge to Robeson Creek from the Pittsboro WWTP. For this purpose of the watershed -based study
requested in this letter, the Town would preliminarily view cost-effectiveness in terms of offsetting or minimizing
the $5.1 million required to construct an effluent pumping station and outfall to the Haw River, and the
associated annual operations and maintenance costs.
Please know that the Town of Pittsboro is committed to meeting the Town's responsibilities to achieve
phosphorus reduction targets established for the Robeson Creek TMDL and the nitrogen and phosphorus
reduction targets established for the Jordan Lake TMDL. However, we believe that a unique opportunity exists
for the Town to work collaboratively with NCDENR staff and other important stakeholder groups to identify
innovative and creative strategies to cost-effectively meet the TMDL requirements through a combination of
planned, coordinated, and targeted nutrient reduction measures for both point and non -point sources of
nitrogen and phosphorus. Our ultimate objectives — in order of priority — will be to:
✓ Meet or exceed the effluent limitations and allocations required by the June 2, 2011 permit renewal
and modification, including the Robeson Creek TMDL for Total Phosphorous and the Jordan Lake TMDL and
✓ Work with your staff and other important stakeholder groups to restore the designated uses of
Robeson Creek via a holistic watershed -based investigation,
✓ Work to address our impaired 303(d) listed water bodies using point and non -point source nutrient
management and education strategies, and;
✓ Receive a renewed permit in 2016 that includes an increase of effluent discharges into Robeson Creek
from the Pittsboro WWTP to the extent it is feasible and based on maintaining the ecological function of the
receiving waters.
Attached to this letter request, are letters of interest from key stakeholder groups that would like to participate
with NCDENR staff and the Town of Pittsboro to identify opportunities to preserve, protect, and restore the
health and condition of Robeson Creek through innovative and alternative approaches. Rest assured, the
Town of Pittsboro has no preconceived expectations regarding the findings of such a watershed -based
investigation, but given the magnitude of the costs for an effluent pumping station and pipeline, and the
importance of Robeson Creek as a community environmental resource, we believe it is in the best interest of
our citizens to make this request of NCDENR at this time.
Thank you very much for considering our request. I look forward to meeting with you and your staff soon to
discuss the feasibility of initiating this proposed watershed -based investigation which will benefit Robeson
Creek, Jordan Lake and the citizens of the Town of Pittsboro.
rely,
MytO
andVo let, Mayor
Town of Pittsboro, North Carolina
Cc: Mr. Dee Freeman, DENR Secretary
Mr. Bryan Gruesbeck, Town Manager
Attachments:
(a) Letter from Haw River Assembly
(b) Letter from Robeson Creek Watershed Council

Robeson Creek
WATERSHED COUNCIL
December 5, 2012
To: Mayor Randy Voller and the Pittsboro Town Board of Commissioners
RE: Letter of support for the Town of Pittsboro's request for a review of the 0.75 mgd
discharge into Robeson Creek
Honorable Mayor and Commissioners,
The Robeson Creek Watershed Council (RCWC) is comprised of stakeholders, including
representatives of federal, state, and local agencies that have worked together since 2001 to find
solutions to the water quality issues in the Robeson Creek watershed. The Robeson Creek
watershed drains all of the incorporated limits of the Town of Pittsboro as well as the majority of
the ETJ. We appreciate the Town's continued support and participation in the RCWC.
Robeson Creek was first placed on the North Carolina State Impaired Waters List (303(d) list) in
1998 for chlorophyll a violations and for a biological impairment on the main stem of Robeson
Creek. A total maximum daily load (TMDL) for total phosphorus was developed for Robeson
Creek in 2003 to address the chlorophyll a violations in the Robeson Creek cove of Jordan Lake.
The TMDL calls for a 71 % phosphorus reduction from urban runoff as well as from the
Pittsboro WWTP. Robeson Creek continues to be listed on the 303 (d) both upstream and
downstream of Pittsboro's WWTP for impaired aquatic life.
After much consideration and discussion of the water quality issues faced by Robeson Creek, the
RCWC would like to express our support for a review of the dual discharge permit the town
received in June 2011 for a 0.75 mgd discharge to Robeson Creek and a 2.47 mgd discharge to
Haw River. We understand that the current permitted discharge of 0.75 mgd into Robeson Creek
is based on the USGS hydrologically based 7Q10 flow, which is the lowest 7-day average flow
in a ten-year period. Robeson Creek like many Carolina slate belt streams tends to have a low
flow especially during the summer months, but unlike many of the surrounding creeks, Robeson
Creek generally does not go dry. Currently there is no flow data for Robeson Creek upstream of
the WWTP for the basis of the 7Q10. We fully support scientific study of Robeson Creek's
stream flow in this critically important stream to more accurately determine this creek's flow so
that appropriate discharge flows into the creek can be agreed on.

The RCWC would be willing to work with Pittsboro and NCDENR on a watershed -based study
to evaluate the possibility of increasing the discharge to Robeson Creek. Ultimately our hope is
for the continued restoration and protection of the ecological integrity of Robeson Creek.
Sincerely,
d4c4-Zae-4-
R0,4"1. Nye. Pk la
Catherine Deininger and Karen Hall, Ph.D.
Co -Coordinators of the Robeson Creek Watershed Council

Haw River Assembly
Defending the river since 1982.
November 28, 2012
To: The Town of Pittsboro,
Mayor Randy Voller and the Pittsboro Board of Commissioners
Subject: Letter of Support for Town of Pittsboro's Request to Review Robeson Creek
Discharge
Dear Mayor Voller and Town of Pittsboro Board of Commissioners:
The Haw River Assembly supports your request to the NC Department of Natural Resources to
review the dual discharge requirements defined in the approved permit renewal and
modification. We agree with your proposal to initiate a watershed -based study to evaluate the
potential to eliminate or modify the dual -discharge requirement and increase the Town of
Pittsboro's discharge to Robeson Creek from 0.75 mgd to a level that is sustainable for the
ecological function of Robeson Creek.
We are aware that improvements to the Robeson Creek Watershed and the Town's need to meet
the Jordan Lake TMDL requirements underpin any changes to the existing WWTP permit for
Pittsboro. We believe there is time and new opportunity to review this dual discharge permit that
will result in a less expensive but more effective approach to Pittsboro's wastewater effluent.
Based on current population projections and the wastewater treatment capacity for Pittsboro it
appears that there is ample time to review better options for water quality and ecosystem health
with a new look at what is possible.
We strongly support the consideration of a modified permit that would significantly reduce the
risk to water quality, aquatic life and recreational use in the Haw River at the Highway 64 site
created by the 2.47 mgd of treated wastewater that was approved in the dual discharge permit
renewal and modification on June 2, 2011. This stretch of river has important Significant
Natural Areas, and rare and endangered species incidences and habitat. It is at the public access
point for the Lower Haw River State Natural Area which is popular for paddling, fishing, tubing
and other recreation. It is only a mile upstream of the impounded waters for Jordan Lake, which
is the focus of efforts to reduce nutrient pollution. Eliminating this Haw River discharge from
the existing permit, while providing sustainable water quality and ecosystem health in Robeson
Creek, would be a win -win for all.

The Town of Pittsboro has a tremendous opportunity to explore the use of proven innovative
approaches to treat and reuse wastewater that would otherwise be discharged into the Haw River.
This reuse quality water could be used throughout their ETJ including proposed new
development. Irrigation reuse and more traditional land application would help restore the local
hydrologic cycle which has been impacted by development, increased water withdrawals, and
direct discharges of treated wastewater effluent into already impaired surface waters.
These and other options could be explored in a more cost-effective and holistic manner to
mitigate the adverse impacts of excessive nutrient loading, restore the designated uses of
Robeson Creek, and accommodate an increased discharge to Robeson Creek from the Pittsboro
WWTP.
The Haw River Assembly would like to work with the Town of Pittsboro and other stakeholders
to identify opportunities to preserve, protect, and restore the health and condition of Robeson
Creek Watershed and receiving streams through innovative and more cost-effective approaches.
We support your proposal to NC DENR for this watershed -based study and to explore better
options for water quality and ecological health.
Sincerely
Elaine Chiosso
Haw Riverkeeper

, (3PEQ Tmage, 1537 x 1177 pixels) - Scaled (67%)
https:l/mail-attachment.googleusercontent.com/attachment'u/0/?ui=2...
• >3.25 MGD Discharge
A/ Associated Subbasins
Counties
Please see the attached map showing NPDES point sources associated with small
watersheds in this general area of NC. As you can see, there are many of these
associated with small streams. Some of these are quite large. Pittsboro is requesting to
establish a new point source discharge into the Haw River near US 64. Presently, they
are discharging to Robeson Creek. This makes no sense. They should keep the point
source where it is.
John Alderman
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1-14 € Pub L1 C- t J "T" 5E55 t oN k,vIt 5 tk E L-O CsA-
tpi "".513 c'1 's Qe,g4% %r 1,
1 of 1
12/19/2012 8:49 AM

TOWN OF
RANDOLPH VOLLER
Mayor
WILLIAM G.TERRY
Town Manager
PAUL MESSICK, JR.
Town Attorney
P.O. BOX 759, 635 EAST ST.
PITTSBORO, NC 27312
December 18, 2012
Secretary Dee Freeman
NC Department of Environment and Natural Resources
512 North Salisbury Street
Raleigh, North Carolina, 27699-1601
l-- ej
l
Li L) i
BOARD OF COMMISSIONERS
PAMELA BALDWIN
J.A. FARRELL
MICHAEL FIOCCO
BETH TURNER
BELT WILSON-FOLEY
TELEPHONE
[phone]
FAX [phone]
Subject: Request to Review the Robeson Creek Discharge for the Town of Pittsboro, NC
Dear Secretary Freeman:
It was a pleasure chatting with you yesterday. Attached you will find a letter the Town of Pittsboro has
sent to DENR regarding the discharge permit to Robeson Creek along with letters from the Robeson
Creek Watershed Council (RCWC) and the Haw River Assembly on the aforesaid topic.
For a variety of sensible environmental, ecological, and economic development reasons, I believe that the
State of North Carolina in conjunction with the various local stakeholders should allow the Town of
Pittsboro to eliminate or modify the dual -discharge requirement and increase the Town of
Pittsboro's discharge to Robeson Creek from 0.75 mgd to a level that is sustainable for the
ecological function of Robeson Creek as well the future of Pittsboro and Chatham County.
The Town currently holds a permit to install a pipe along Robeson Creek for many miles to the east and
ultimately discharge an additional 2.47 mgd of effluent into the Haw River.
Besides the extra cost of installing the aforesaid pipe, it is apparent that the installation will potentially
damage the creek buffers and ultimately the discharge at the Haw River may be less preferable than
permitting a greater discharge of effluent at the Town's current location.
It seems logical that a better interim solution would be to allow the Town's updated WWTP plant (we
currently produce reuse quality effluent) to discharge a reasonable amount more at its current location,
while other potential solutions and partnerships are evaluated. (I have attached a map from biologist John
Alderman that shows the millions of gallons of effluent already permitted in other watersheds in North
Carolina that are potentially comparable to ours.) I hope you can grant that request.
CHARTERED 1787

Mr. Dee Freeman, Secretary, NCDENR
Request to Review Robeson Creek Discharge for Pittsboro, NC
date
Page 2 of 2
Thank you very much for considering our request. Occasionally situations arise where good public policy
can align fiscal prudence with the potential for better long term environmental stewardship. This situation
appears to meet that criteria, which has prompted my letter to your office.
I am happy to meet with you in person or chat on the phone regarding our proposal at 949-1274.
Si
Vteek._
R- dy Volier, Mayor
Twn of Pittsboro, North Carolina
CC: Mr. Bryan Gruesbeck, Town Manager
Attachments:
(a) Letter to Chuck
(b) Letter from Haw River Assembly
(c) Letter from Robeson Creek Watershed Council
(d) Map from John Alderman

TOWN OF
RANDOLPH VOLLER
Mayor
BRYAN L. GRUESBECK
Town Manager
PAUL S. MESSICK, JR.
Town Attomey
P.O. Box 759 — 635 East Street
PITTSBORO, N.C. 27312
December 10, 2012
Mr. Chuck Wakild, Director
Division of Water Quality
NC Department of Environment and Natural Resources
512 North Salisbury Street
Raleigh, North Carolina,"27699-1601
BOARD OF COMMISSIONERS
PAMELA BALDWIN
JAY FARRELL
MICHAEL A. FIOCCO
BETT WILSON FOLEY
BETH TURNER
TELEPHONE
[phone]
FAX [phone]
S ibrebtr"Regl:restto Review Rcstsesan Creek Discharge for Town of Pittsburg,
Dear Mr. Wakild:
The Town of Pittsboro, NC is fortunate to see early signs of growth and development return to the heart of
North Carolina's Piedmont region. As expected, we here in Pittsboro are excited about new economic
development opportunities which will add to our rich quality of life and our local business community.
However, we are mindful of our responsibility to preserve, protect, and restore the important environmental
resources of the community that contribute to the rich quality of life afforded in Pittsboro.
We are very grateful to the staff of the North Carolina Department of Environment and Natural Resources
(NCDENR) for working closely with the Town of Pittsboro to process our Environmental Impact Statement
(EIS) for a wastewater treatment plant expansion project that included a dual discharge to Robeson Creek
(0.75 mgd) and the Haw River (2.47 mgd). The Record of Decision (ROD) for the EIS was issued on March
29, 2010, and the Town received approval for the permit renewal and modification on June 2, 2011. Once
again, I want to extend my sincere appreciation to NCDENR staff for taking the time to work with -the Town to
achieve this significant milestone for the current and future citizens of Pittsboro.
Since receiving the approved permit renewal and modification on June 2, 2011, the Town has been working to
evaluate options to implement the wastewater treatment upgrade and expansion project with a dual discharge
to Robeson Creek and the Haw River. In August 2012, the Town Board of Commissioners received an
engineering report indicating that the capital cost for the discharge to the Haw River was approximately $5.1
million. Given the scope, scale, and nature of this project and the associated costs, the Town of Pittsboro
respectfully requests an opportunity to meet with you and representatives of your staff to review the dual
discharge requirements defined in the approved permit renewal and modification. Specifically, the Town would
like to discuss the possibility of working with NCDENR and other stakeholders on a watershed -based study to
evaluate the potential to eliminate or modify the dual -discharge requirement and increase the Town of
Pittsboro's discharge to Robeson Creek from 0.75 mgd to a level that is sustainable for the ecological function
of Robeson Creek.
In making this request to collaborate on a watershed -based study, the Town clearly understands that Robeson
Creek was listed as an impaired water body on the 2010 North Carolina 303(d) Impaired Waters List, and that
impairment is related to habitat degradation contributions from both non -point and point sources. However, we
would very much like to work with NCDENR staff and representatives from the Robeson Creek Watershed
Council (RCWC), the Haw River Assembly, the NCSU School of Biological and Agricultural Engineering
CHARTERED 1787

Mr. Chuck Wakild, Director, NCDENR
December 10, 2012
Page 2 of 2
Department, and other stakeholders to identify the optimum combination of point- and non -point source
nutrient reduction measures that can be cost-effectively implemented to mitigate the adverse impacts of
excessive nutrient loading, restore the designated uses of Robeson Creek, and accommodate an increased
discharge to Robeson Creek from the Pittsboro WWTP. For this purpose of the watershed -based study
requested in this letter, the Town would preliminarily view cost-effectiveness in terms of offsetting or minimizing
the $5.1 million required to construct an effluent pumping station and outfall to the Haw River, and the
associated annual operations and maintenance costs.
Please know that the Town of Pittsboro is committed to meeting the Town's responsibilities to achieve
phosphorus reduction targets established for the Robeson Creek TMDL and the nitrogen and phosphorus
reduction targets established for the Jordan Lake TMDL. However, we believe that a unique opportunity exists
for the Town to work collaboratively with NCDENR staff and other important stakeholder groups to identify
innovative and creative strategies to cost-effectively meet the TMDL requirements through a combination of
planned, coordinated, and targeted nutrient reduction measures for both point and non -point sources of
nitrogen and phosphorus. Our ultimate objectives — in order of priority — will be to:
✓ Meet or exceed the effluent limitations and allocations required by the June 2, 2011 permit renewal
and modification, including the Robeson Creek TMDL for Total Phosphorous.and the Jordan.Lake TMDL and
✓ Work with your staff and other important stakeholder groups to restore the designated uses of .
Robeson Creek via a holistic watershed -based investigation,
• Work to address our impaired 303(d) listed water bodies using point and non -point source nutrient
management and education strategies, and;
✓ Receive a renewed permit in 2016 that includes an increase of effluent discharges into Robeson Creek
from the Pittsboro WWTP to the extent it is feasible and based on maintaining the ecological function of the
receiving waters.
Attached to this letter request, are letters of interest from key stakeholder groups that would like to participate
with NCDENR staff and the Town of Pittsboro to identify opportunities to preserve, protect, and restore the
health and condition of Robeson Creek through innovative and alternative approaches. Rest assured, the
Town of Pittsboro has no preconceived expectations regarding the findings of such a watershed -based
investigation, but given the magnitude of the costs for an effluent pumping station and pipeline, and the
importance of Robeson Creek as a community environmental resource, we believe it is in the best interest of
our citizens to make this request of NCDENR at this time.
Thank you very much for considering our request. I look forward to meeting with you and your staff soon to
discuss the feasibility of initiating this proposed watershed -based investigation which will benefit Robeson
Creek, Jordan Lake and the citizens of the Town of Pittsboro.
rely,
and vo leNi, Mayor
Town of Pittsboro, North Carolina
tt0
. Cc: Mr. Dee Freeman, DENR Secretary
Mr. Bryan Gruesbeck, Town Manager
Attachments:
(a) Letter from Haw River Assembly
(b) Letterfrom Robeson Creek Watershed Council

Robeson Creek
WATERSHED COUNCIL
December 5, 2012
To: Mayor Randy Voller and the Pittsboro Town Board of Commissioners
RE: Letter of support for the Town of Pittsboro's request for a review of the 0.75 mgd
discharge into Robeson Creek
Honorable Mayor and Commissioners,
The Robeson Creek Watershed Council (RCWC) is comprised of stakeholders, including
representatives of federal, state, and local agencies that have worked together since 2001 to find
solutions to the water quality issues in the Robeson Creek watershed. The Robeson Creek
watershed drains all of the incorporated limits of the Town of Pittsboro as well as the majority of
the ETJ. We appreciate the Town's continued support and participation in the RCWC.
Robeson Creek was first placed on the North Carolina State Impaired Waters List (303(d) list) in
1998 for chlorophyll a violations and for a biological impairment on the main stem of Robeson
Creek. A total maximum daily load (TMDL) for total phosphorus was developed for Robeson
Creek in 2003 to address the chlorophyll a violations in the Robeson Creek cove of Jordan Lake.
The TMDL calls for a 71 % phosphorus reduction from urban runoff as well as from the
Pittsboro WWTP. Robeson Creek continues to be listed on the 303 (d) both upstream and
downstream of Pittsboro's WWTP for impaired aquatic life.
After much consideration and discussion of the water quality issues faced by Robeson Creek, the
RCWC would like to express our support for a review of the dual discharge permit the town
received in June 2011 for a 0.75 mgd discharge to Robeson Creek and a 2.47 mgd discharge to
Haw River. We understand that the current permitted discharge of 0.75 mgd into Robeson Creek
is based on the USGS hydrologically based 7Q10 flow, which is the lowest 7-day average flow
in a ten-year period. Robeson Creek like many Carolina slate belt streams tends to have a low
flow especially during the summer months, but unlike many of the surrounding creeks, Robeson
Creek generally does not go dry. Currently there is no flow data for Robeson Creek upstream of
the WWTP for the basis of the 7Q10. We fully support scientific study of Robeson Creek's
stream flow in this critically important stream to more accurately determine this creek's flow so
that appropriate discharge flows into the creek can be agreed on.

The RCWC would be willing to work with Pittsboro and NCDENR on a watershed -based study
to evaluate the possibility of increasing the discharge to Robeson Creek. Ultimately our hope is
for the continued restoration and protection of the ecological integrity of Robeson Creek.
Sincerely,
2/.L'";Y:"
kam,l, Nam. Pia
Catherine Deininger and Karen Hall, Ph.D.
Co -Coordinators of the Robeson Creek Watershed Council

November 28, 2012
To: The Town of Pittsboro,
Mayor Randy Voller and the Pittsboro Board of Commissioners
Subject: Letter of Support for Town of Pittsboro's Request to Review Robeson Creek
Discharge
Dear Mayor Voller and Town of Pittsboro Board of Commissioners:
The Haw River Assembly supports your request to the NC Department of Natural Resources to
review the dual discharge requirements defined in the approved permit renewal and
modification. We agree with your proposal to initiate a watershed -based study to evaluate the
potential to eliminate or modify the dual -discharge requirement and increase the Town of
Pittsboro's discharge to Robeson Creek from 0.75 mgd to a level that is sustainable for the
ecological function of Robeson Creek.
We are aware that improvements to the Robeson Creek Watershed and the Town's need to meet
the Jordan Lake TMDL requirements underpin any changes to the existing WWTP permit for
Pittsboro. We believe there is time and new opportunity to review this dual discharge permit that
will result in a less expensive but more effective approach to Pittsboro's wastewater effluent.
Based on current population projections and the wastewater treatment capacity for Pittsboro it
appears that there is ample time to review better options for water quality and ecosystem health
with a new look at what is possible.
We strongly support the consideration of a modified permit that would significantly reduce the
risk to water quality, aquatic life and recreational use in the Haw River at the Highway 64 site
created by the 2.47 mgd of treated wastewater that was approved in the dual discharge permit
renewal and modification on June 2, 2011. This stretch of river has important Significant
Natural Areas, and rare and endangered species incidences and habitat. It is at the public access
point for the Lower Haw River State Natural Area which is popular for paddling, fishing, tubing
and other recreation. It is only a mile upstream of the impounded waters for Jordan Lake, which
is the focus of efforts to reduce nutrient pollution. Eliminating this Haw River discharge from
the existing permit, while providing sustainable water quality and ecosystem health in Robeson
Creek, would be a win -win for all.

The Town of Pittsboro has a tremendous opportunity to explore the use of proven innovative
approaches to treat and reuse wastewater that would otherwise be discharged into the Haw River.
This reuse quality water could be used throughout their ETJ including proposed new
development. Irrigation reuse and more traditional land application would help restore the local
hydrologic cycle which has been impacted by development, increased water withdrawals, and
direct discharges of treated wastewater effluent into already impaired surface waters.
These and other options could be explored in a more cost-effective and holistic manner to .
mitigate the adverse impacts of excessive nutrient loading, restore the designated uses of
Robeson Creek, and accommodate an increased discharge to Robeson Creek from the Pittsboro
WWTP.
The Haw River Assembly would like to work with the Town of Pittsboro and other stakeholders
to identify opportunities to preserve, protect, and restore the health and condition of Robeson
Creek Watershed and receiving streams through innovative and more cost-effective approaches.
We support your proposal to NC DENR for this watershed -based study and to explore better
options for water quality and ecological health.
Sincerely
Elaine Chiosso
Haw Riverkeeper

(JPEG Image, l537 x 1177 pixels) - Scaled (67%)
https:!lmail-attaclunent.googleusercontent.comiattachmenbbu/Oi?v='2:..,
• ED
18.oe000
• >3.25 MGD Discharge
A/ Associated Subbasins
Counties
0 50 Miles
MEMENBLIRG
15.00000
Please see the attached map showing NPDES point sources associated with small
watersheds in this general area of NC. As you can see, there are many of these
associated with small streams. Some of these are quite large. Pittsboro is requesting to
establish a new point source discharge into the Haw River near US 64. Presently, they
are discharging to Robeson Creek This makes no sense. They should keep the point
source where it is.
John Alderman
--rots WAS F'o t ()ol0'3 fivtetuL 1-1.6 Sew i
T� to Lt C tN vT 5C35 L op w,k S L-io lez G—ate t ivCs—
ipr' 5t3 c'Rc s P- 'c"r
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1 of 1
12/19/2012 8:49 AM

Belnick, Tom
From: Wakild, Chuck
Sent: Wednesday, December 19, 2012 1:51 PM
To: Matthews, Matt
Cc: Smith, Danny; Poupart, Jeff; Belnick, Tom; Bush, Ted
Subject: FW: Letter from Mayor Voller Request to Review Robeson Creek Discharge for Town of
Pittsboro
Attachments: 12.19.12 Mayor Voller Request to review Robeson Creek Discharge for Town of Pittsboro.pdf
Importance: High
Matt - Let's discuss asap. The letter dated December 10 addressed to me arrived on the 17th and I have the hard copy
in my office.
From: Jones, Lori
Sent: Wednesday, December 19, 2012 1:38 PM
To: Wakild, Chuck; Bush, Ted
Cc: Smith, Robin; Bownes, Janice H
Subject: Letter from Mayor Voller Request to Review Robeson Creek Discharge for Town of Pittsboro
Importance: High
Chuck, please see the attached and brief the secretary on this matter (either by phone or in person whatever you prefer
is fine). He is available this afternoon or tomorrow before noon. Thank you.
AIWA
CDft
Lori Jones [e-mail]
Executive Assistant to Secretary Dee Freeman & Chief Deputy Secretary Mary Penny Thompson
North Carolina Department of Environment and Natural Resources
Street Address: 217 W Jones Street, 5t floor, Room 5314-D, RaIeigh, NC 27603-6100
Mailing Address: 1601 Mail Service Center, Raleigh, NC 27699-1601
Telephone: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
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TOWN OF
RANDOLPH VOLLER
Mayor
BRYAN L. GRUESBECK
Town Manager
PAUL S. MESSICK, JR.
Town Attomey
P.O. Box 759 — 635 East Street
PITTSBORO, N.C. 27312
December 10, 2012
Mr. Chuck Wakild, Director
Division of Water Quality
NC Department of Environment and Natural Resources
512 North Salisbury Street
Raleigh, North Carolina, 27699-1601
Subject: Request to Review Robeson Creek Discharge for Town of Pittsboro, NC
`gyp:
i'. := .
7 / .-----
BOARD OF COMMISSIONERS
t.
'PAMELA BALDWIN
�-- �'f I JAY FARRELL
,, MICHAEL A. FIOCCO
BETT WILSON FOLEY
BETH TURNER
TELEPHONE
[phone]
FAX [phone]
ti°
Dear Mr. Wakild:
The Town of Pittsboro, NC is fortunate to see early signs of growth and development return to the heart of
North Carolina's Piedmont region. As expected, we here in Pittsboro are excited about new economic
development opportunities which will add to our rich quality of life and our local business community.
However, we are mindful of our responsibility to preserve, protect, and restore the important environmental
resources of the community that contribute to the rich quality of life afforded in Pittsboro.
We are very grateful to the staff of the North Carolina Department of Environment and Natural Resources
(NCDENR) for working closely with the Town of Pittsboro to process our Environmental Impact Statement
(EIS) for a wastewater treatment plant expansion project that included a dual discharge to Robeson Creek
(0.75 mgd) and the Haw River (2.47 mgd). The Record of Decision (ROD) for the EIS was issued on March
29, 2010, and the Town received approval for the permit renewal and modification on June 2, 2011. Once
again, I want to extend my sincere appreciation to NCDENR staff for taking the time to work with the Town to
achieve this significant milestone for the current and future citizens of Pittsboro.
Since receiving the approved permit renewal and modification on June 2, 2011, the Town has been working to
evaluate options to implement the wastewater treatment upgrade and expansion project with a dual discharge
to Robeson Creek and the Haw River. In August 2012, the Town Board of Commissioners received an
engineering report indicating that the capital cost for the discharge to the Haw River was approximately $5.1
million. Given the scope, scale, and nature of this project and the associated costs, the Town of Pittsboro
respectfully requests an opportunity to meet with you and representatives of your staff to review the dual
discharge requirements defined in the approved permit renewal and modification. Specifically, the Town would
like to discuss the possibility of working with NCDENR and other stakeholders on a watershed -based study to
evaluate the potential to eliminate or modify the dual -discharge requirement and increase the Town of
Pittsboro's discharge to Robeson Creek from 0.75 mgd to a level that is sustainable for the ecological function
of Robeson Creek.
In making this request to collaborate on a watershed -based study, the Town clearly understands that Robeson
Creek was listed as an impaired water body on the 2010 North Carolina 303(d) Impaired Waters List, and that
impairment is related to habitat degradation contributions from both non -point and point sources. However, we
would very much like to work with NCDENR staff and representatives from the Robeson Creek Watershed
Council (RCWC), the Haw River Assembly, the NCSU School of Biological and Agricultural Engineering
CHARTERED 1787

Mr. Chuck Wakild, Director, NCDENR
December 10, 2012
Page 2 of 2
Department, and other stakeholders to identify the optimum combination of point- and non -point source
nutrient reduction measures that can be cost-effectively implemented to mitigate the adverse impacts of
excessive nutrient loading, restore the designated uses of Robeson Creek, and accommodate an increased
discharge to Robeson Creek from the Pittsboro WWTP. For this purpose of the watershed -based study
requested in this letter, the Town would preliminarily view cost-effectiveness in terms of offsetting or minimizing
the $5.1 million required to construct an effluent pumping station and outfall to the Haw River, and the
associated annual operations and maintenance costs.
Please know that the Town of Pittsboro is committed to meeting the Town's responsibilities to achieve
phosphorus reduction targets established for the Robeson Creek TMDL and the nitrogen and phosphorus
reduction targets established for the Jordan Lake TMDL. However, we believe that a unique opportunity exists
for the Town to work collaboratively with NCDENR staff and other important stakeholder groups to identify
innovative and creative strategies to cost-effectively meet the TMDL requirements through a combination of
planned, coordinated, and targeted nutrient reduction measures for both point and non -point sources of
nitrogen and phosphorus. Our ultimate objectives — in order of priority — will be to:
✓ Meet or exceed the effluent limitations and allocations required by the June 2, 2011 permit renewal
and modification, including the Robeson Creek TMDL for Total Phosphorous and the Jordan Lake TMDL and
wastewater rule
✓ Work with your staff and other important stakeholder groups to restore the designated uses of
Robeson Creek via a holistic watershed -based investigation,
•� Work to address our impaired 303(d) listed water bodies using point and non -point source nutrient
management and education strategies, and;
✓ Receive a renewed permit in 2016 that includes an increase of effluent discharges into Robeson Creek
from the Pittsboro WWTP to the extent it is feasible and based on maintaining the ecological function of the
receiving waters.
Attached to this letter request, are letters of interest from key stakeholder groups that would like to participate
with NCDENR staff and the Town of Pittsboro to identify opportunities to preserve, protect, and restore the
health and condition of Robeson Creek through innovative and alternative approaches. Rest assured, the
Town of Pittsboro has no preconceived expectations regarding the findings of such a watershed -based
investigation, but given the magnitude of the costs for an effluent pumping station and pipeline, and the
importance of Robeson Creek as a community environmental resource, we believe it is in the best interest of
our citizens to make this request of NCDENR at this time.
Thank you very much for considering our request. I look forward to meeting with you and your staff soon to
discuss the feasibility of initiating this proposed watershed -based investigation which will benefit Robeson
Creek, Jordan Lake and the citizens of the Town of Pittsboro.
rely,
and yor
Town of Pittsboro, North Carolina
Cc: Mr. Dee Freeman, DENR Secretary
Mr. Bryan Gruesbeck, Town Manager
Attachments:
(a) Letter from Haw River Assembly
(b) Letter from Robeson Creek Watershed Council

obeson Creek
WATERSHED COUNCIL
December 5, 2012
To: Mayor Randy Voller and the Pittsboro Town Board of Commissioners
RE: Letter of support for the Town of Pittsboro's request for a review of the 0.75 mgd
discharge into Robeson Creek
Honorable Mayor and Commissioners,
The Robeson Creek Watershed Council (RCWC) is comprised of stakeholders, including
representatives of federal, state, and local agencies that have worked together since 2001 to find
solutions to the water quality issues in the Robeson Creek watershed. The Robeson Creek
watershed drains all of the incorporated limits of the Town of Pittsboro as well as the majority of
the ETJ. We appreciate the Town's continued support and participation in the RCWC.
Robeson Creek was first placed on the North Carolina State Impaired Waters List (303(d) list) in
1998 for chlorophyll a violations and for a biological impairment on the main stem of Robeson
Creek. A total maximum daily load (TMDL) for total phosphorus was developed for Robeson
Creek in 2003 to address the chlorophyll a violations in the Robeson Creek cove of Jordan Lake.
The TMDL calls for a 71 % phosphorus reduction from urban runoff as well as from the
Pittsboro WWTP. Robeson Creek continues to be listed on the 303 (d) both upstream and
downstream of Pittsboro's WWTP for impaired aquatic life.
After much consideration and discussion of the water quality issues faced by Robeson Creek, the
RCWC would like to express our support for a review of the dual discharge permit the town
received in June 2011 for a 0.75 mgd discharge to Robeson Creek and a 2.47 mgd discharge to
Haw River. We understand that the current permitted discharge of 0.75 mgd into Robeson Creek
is based on the USGS hydrologically based 7Q10 flow, which is the lowest 7-day average flow
in a ten-year period. Robeson Creek like many Carolina slate belt streams tends to have a low
flow especially during the summer months, but unlike many of the surrounding creeks, Robeson
Creek generally does not go dry. Currently there is no flow data for Robeson Creek upstream of
the WWTP for the basis of the 7Q10. We fully support scientific study of Robeson Creek's
stream flow in this critically important stream to more accurately determine this creek's flow so
that appropriate discharge flows into the creek can be agreed on.

The RCWC would be willing to work with Pittsboro and NCDENR on a watershed -based study
to evaluate the possibility of increasing the discharge to Robeson Creek. Ultimately our hope is
for the continued restoration and protection of the ecological integrity of Robeson Creek.
Sincerely,
Nam, PJJ.
Catherine Deininger and Karen Hall, Ph.D.
Co -Coordinators of the Robeson Creek Watershed Council