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HomeMy WebLinkAboutNC0063096_Speculative Limits_20110624NPDES DOCVNENT SCANNING COVER SHEET NC0063096 Holly Springs WWTP NPDES Permit: Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change Meeting Notes Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: June 24, 2011 This document is printed on reuse paper - igIzore any content on the re'rerse side Beverly Eaves Perdue Governor North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director June 24, 2011 Ms. Stephanie L. Sudano, P.E. Director of Engineering Town of Holly Springs P.O. Box 8 Holly Springs, North Carolina 27540 Subject: Speculative Effluent Limits Holly Springs WWTP Permit No. NC0063096 Wake County Cape Fear River Basin Dear Ms. Sudano: Dee Freeman Secretary This letter provides speculative effluent limits of 6 MGD (Phase I) and 8 MGD (Phase II) for the Holly Springs WWTP, which is currently permitted to discharge up to 2.4 MGD to Utley Creek. The Division received the speculative limits request in an email dated June 21, 2011 from Bill Kreutzberger of CH2M HILL. The requested discharge location is further downstream in Utley Creek below Greentree Reservoir (location B in the CH2M Technical Memorandum dated June 21, 2011). Previously, speculative limits were provided for a discharge directly to Harris Lake (letter dated February 23, 2010). Please recognize that speculative limits may change based on future water quality initiatives, and it is highly recommended that the applicant verify the speculative limits with the Division's NPDES Unit prior to any engineering design work. Receiving Stream. Utley Creek is located within the Cape Fear River Basin. Utley Creek has a stream classification of C, and waters with this classification have a best usage for aquatic life propagation and maintenance of biological integrity, wildlife, secondary recreation and agriculture. Utley Creek has a summer 7Q10 flow of 0.11 cfs at the current discharge location based on USGS 1993 data. Utley Creek is not listed as an impaired waterbody on the 2010 North Carolina 303(d) Impaired Waters List. The current discharge enters the headwaters of Utley Creek. Below the current discharge point, the discharge enters Thomas Mill Pond which is shallow and subject to algal blooms. Further downstream in Utley Creek is Greentree Reservoir, and there is some uncertainty regarding the outlet flow regime that will be operated by Progress Energy. Hence, to alleviate water quality concerns similar to Thomas Mill Pond, this speculative request is for a discharge point directly below Greentree Reservoir and approximately 0.7 miles from the White Oak Creek arm of Harris Lake (at its current level of 220' MSL). Harris Lake is a manmade reservoir that provides cooling, process, and domestic water for the Shearon Harris Nuclear Power Plant. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh. North Carolina 27604 Phone: 919-807-6300 ! FAX: 919-807-64921 Customer Service: 1-877-623-6748 Internet: www.ncwaterctuaiitv.orq NorthCarolina Naturally Speculative Effluent Limits. Based on Division review of receiving stream conditions, CE-QUAL-W2 lake response modeling, and QUAL2E-UNCAS stream modeling, speculative limits for the proposed expansion to 6 MGD and 8 MGD are presented in Table 1. A complete evaluation of these Limits and effluent/instream monitoring requirements will be addressed upon receipt of a formal NPDES permit application. Some features of the speculative limit development include the following: • Nutrient Limits. Speculative nutrient limits are based on a nutrient response model developed for discharge to Harris Lake. The model indicates that Harris Lake is highly responsive to phosphorus. • BOD, NH3, DO Limits. Modeling indicates that there is very little impact on the dissolved oxygen concentrations in the hypolimnion of Harris Lake with these proposed limits. TABLE 1. Speculative Limits for Holly Springs WWTP (Proposed Expansion to 6 & 8 MGD) Effluent Characteristic Effluent Limitations Monthly Average Weekly Average Daily Maximum Flow 6 or 8 MGD BOD5 5.0 mg/ L 7.5 mg/ L NH3 as N 1.0 mg/L 3.0 mg/ L TSS 30 mg/ L 45 mg/ L TRC 28 ug/1 Fecal coliform (geometric mean) 200/100 ml 400/100 ml Dissolved Oxygen 7.0 mg/I (Daily Average, Minimum) pH 6.0 to 9.0 standard units Total Nitrogen 5.0 mg N/1 Total Phosphorus 0.5 mg/ I Ortho Phosphorus 0.27 mg/1 Chronic Toxicity Pass/Fail 90% Engineering Alternatives Analysis (EAA). Please note that the Division cannot guarantee that an NPDES permit for an expanded discharge will be issued with these speculative limits. Final decisions can only be made after the Division receives and evaluates a formal permit application for the expanded discharge. In accordance with the North Carolina General Statutes, the practicable wastewater treatment and disposal alternative with the least adverse impact on the environment is required to be implemented. Therefore, as a component of all NPDES permit applications for new or expanding flow, a detailed engineering alternatives analysis (EAA) must be prepared. The EAA must justify requested flows and provide an analysis of potential wastewater treatment alternatives. A copy of Division guidance for preparing EAA documents is attached. State Environmental Policy Act (SEPA) EA/EIS Requirements. A SEPA EA/EIS document must be prepared for all projects that: 1) need a permit; 2) use public money or affect public lands; and 3) might have a potential to significantly impact the environment. For existing discharges, significant impact is defined as an expansion of > 500,000 gpd additional flow. Since the Town of Holly Springs is proposing an expansion >500,000 gpd flow, the Town must prepare a SEPA document that evaluates the potential for impacting the quality of the environment. The NPDES Unit will not accept an NPDES permit application for the expanded discharge until the Division has approved the SEPA document and sent a Finding of No Significant Impact (FONSI) to the State Clearinghouse for review and comment. A SEPA Environmental Assessment (EA) should contain a clear justification for the proposed project. If the SEPA EA demonstrates that the project may result in a significant adverse effect on the quality of the environment, you must then prepare a SEPA EIS (Environmental Impact Statement). Since your expanded discharge is subject to SEPA, the EAA requirements discussed above will need to be folded into the SEPA document. The SEPA process will be delayed if all EAA requirements are not adequately addressed. If you have any questions regarding SEPA EA/EIS requirements, please contact Hannah Stallings with the DWQ Planning Branch at (919) 807-6434. Should you have any questions about these speculative limits or NPDES permitting requirements, please feel free to contact me (919) 807-6390. Res . ectfulleJl*C— m Belnick Supervisor, NPDES Complex Permitting Unit Hardcopy: US Fish and Wildlife Service, Ecological Services, PO Box 33726, Raleigh, NC 27636-3726 Attn: Sara Myers NC WRC, Inland Fisheries, 1721 Mail Service Center, Raleigh, NC, 27699-1721 Attn: Fred Harris Central Files NPDES Permit File/NC0063096 Email Copy: Danny Smith/DWQ Raleigh Regional Office Kathy Stecker/Modeling TMDL Unit Hannah Stallings/ DWQ SEPA Bill Kreutzberger/CH2M HILL Stephanie Sudano/Holly Springs Chuck Wakild/DWQ Matt Matthews/DWQ SWPS Jeff Poupart/DWQ PSB NPDES Server/Spec Limits TAr1411917(# c(zoii Belnick, Tom From: Sent: To: Subject: Stecker, Kathy Wednesday, June 22, 2011 4:32 PM Belnick, Tom HS MTU cannot make any definitive statements about the potential impact of the Holly Springs discharge below Green Tree Reservoir on dissolved oxygen concentrations based on the currently submitted model due to the following areas of uncertainty: 1. Uncertain flow estimate. Flow estimates are uncertain as documented in: a. "Flow Estimates on Utley Creek" meeting summary memo (CH2MHi11, May 9, 2011), b. an email from Bill Kreutzberger to Tom Belnick on May 25, 4:46 pm, and c. "Evaluation of Proposed Utley Creek Discharge" memo (CH2MHill, June 21, 2011). 2. Only one calibration point. There are only two monitoring stations within the model extent. The first is UTC-5 just below Thomas Millpond, which was used to develop headwater characteristics. This leaves one station available to calibrate the model. This second station is UTC-7, approximately 1.1 miles downstream of Thomas Mill Pond and near the location of the proposed discharge (below Green Tree, 0.7 miles from Harris Lake). Additional calibration points would reduce uncertainty and provide confidence that the model is accurately predicting the spatial distribution of DO concentrations. 3. Only one data point. Because the Qual2e model represents steady state conditions, only one monitoring data point (DO = 8.0 mg/L on 8/25/09) was used to calibrate the model. DO monitoring data collected during the summer (defined as May — September) at UTC-7 range from 6.4 (8/15/09) to 13.5 mg/L (7/9/10). The model should have been evaluated for other data points measured during summer months. Bottom Line The modeling was based on uncertain flow, one calibration point, and one data point. Adequate data could only be acquired with additional field study and installation of a flow gage. The proposed discharge is 0.7 miles above Harris Lake, and we have already determined that the downstream arm of Harris Lake can assimilate the proposed discharge. Based on this proximity, but not on modeling results, you may want to consider spec limits equal to the spec limits issued for direct discharge to Harris Lake. i 14$164Pfor &roll t Ale OCID (13ocil TECHNICAL MEMORANDUM GIH2MHILL Evaluation of Proposed Utley Creek Discharge PREPARED FOR: NC Division of Water Quality PREPARED BY: Klaus Albertin\ CH2M HILL COPIES: Stephanie Sudano\Town of Holly Springs Bill Kreut verger\ CH2M HILL DATE: Background The Town of Holly Springs ("Town") is evaluating wastewater treatment and disposal options to meet their growing demands. The Town current' dischar es effluent from their water a lu a,tPQ f1cihtaWRF) to the headwat f„�T y„ tri to the to ,..0.41rXrakarrm of Harris Lae. own has received speculative limits for a discharge to the White Oak Creearm of Harris Lake. The Town is interested in exploring the potential for an alternative discharge location to Utley Creek below Thomas Mil Pond or Greentree Reservoir. Discharging to Utley Creek will result in a shorter effluent line, less habitat disturbance, lower greenhouse gas emissions, and resulting lower capital and operating costs. This alternative has already been evaluated in a draft Environmental Assessment (EA); however review of this EA/alternative by the North Carolina Division of Water Quality (DWQ) and other state/federal agencies cannot proceed until speculative limits have been issued for this discharge location. This memo describes the approach used to provide technical support for a decision regarding speculative effluent limits. Approach The QUAL2E-UNCAS model was used to evaluate the potential impacts to dissolved oxygen (DO) concentrations as a result of the proposed discharge below either the Thomas Mill Pond or Greentree Reservoir locations. QUAL2E-UNCAS is steady state stream water quality model that is widely applied to support this type of evaluation (US EPA, 1987). The first proposed discharge location (Location A) is directly below Thomas Mill Pond and approximately 1.7 miles from the lake at its current level of 220' MSL and approximately 1.1 miles from the 240' MSL contour if the lake is raised to support expansion of the Shearon Harris Nuclear Power facilities (see Attachment A-1). The second proposed discharge location (Location B is direct' below Greentre n • t 0.7 miles 'from the lake at its current level of 220' MSL and at the 240' MSL contour if the lake is raised to support expansion of the Shearon Harris Nuclear Model Setup ties (see Attachment The model requires stream geometry, meteorological inputs, inflow information, instream observations, and point source characteristics to predict instream water quality. The QUAL2E model was setup to represent Utley Creek for a calibration period and for b/toli COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE evaluating the proposed discharge during critical conditions; 7-day, 10-year low flow (7Q10 flow) and summer temperatures. Stream Visit Utley Creek is regularly visited as part of an ongoing monitoring program; however, a more detailed field examination was performed on February 18th, 2011. The stream was walked from the proposed discharge location below Thomas Mill Pond to its confluence with the White Oak Arm of Harris Lake. Estimates of geometry were determined at regular intervals and at areas where the stream characteristics changed significantly. The creek was highly variable with sections changing from wide, straight, shallow areas to meandering, narrower, pooled sections. Based on the field observations, the model was split into three distinct reaches. The characteristics as generalized in the model are provided in Tables 1 and 2. TABLE 1 Utley Creek Reach Characteristics Reach Segment Length (mi) Width (ft) Depth (ft) Type Thomas Mill Pond 0.8 12 1 Relatively wide and straight, to 1st Tributary occasional impedances from vegetation or geology — moderate Manning's n 1st Tributary to 2nd 0.5 10 1 - 2 Meandering with a few deeper Tributary pools— higher Manning's n 2nd Tributary to Harris Lake 0.4 15 1 Meandering but wider with fewer pools, backwater near confluence with Harris Lake — moderate Manning's n TABLE 2 Utley Creek Reach Characteristics Reach Segment Top Elevation (ft) Bottom Elevation (ft) Slope (ft/ft) Manning's n Thomas Mill Pond 262 248 to 1st Tributary 1st Tributary to 2nd 248 238 Tributary 2nd Tributary to 238 220 Harris Lake 0.0065 0.0037 0.0043 0.035 0.040 0.035 2 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Inflow Utley Creek is not monitored for flow. The current NPDES permit for the Utley Creek WWTP is based on a 7Q10 value of 0.11 cfs. In researching this value, it was based on an analysis by USGS that used three stations in the Raleigh area and the actual rate identified by USGS was 0.11 cfs/mil (Personal Communication with USGS, 2011). This rate was used to estimate a 7Q10 flow value for the new discharge location of 0.24 cfs based on the drainage area of 2.25 mi2. Scaling of flows from the USGS gage on Middle Creek near Clayton (USGS 02088000) was used to develop a surrogate flow timeseries for Utley Creek for use in model calibration. The Middle Creek watershed at this gage was identified as having similar characteristics as the Utley Creek watershed although the Middle Creek flows are somewhat augmented by discharges. The Utley Creek flows were estimated by scaling the Middle Creek flows by the ratio of the drainage areas. The relevant information for this approach is provided in Table 3. The uncertainty analysis component (UNCAS) will be used to provide the estimate of the impacts that these assumptions will have on model results. The Middle Creek gage data was used to determine an appropriate time period for selecting data from the monitoring program for model calibration. Review of the gage data indicated that the lowest flow during the water quality monitoring period for Utley Creek occurred in August 2009 as shown in Figure 1. As described in the next section, dates when monitoring was performed were identified to select a specific calibration date. TABLE 3 Drainage Area Ratios Used for Calibration Flow Estimates of Utley Creek Middle Ck Utley Creek Utley Creek Trib Trib Total Direct drainage Direct drainage 1 2 below TMP above TMP Drainage (ac) 53,440 319.6 1437.7 178.6 463.6 2399.5 Drainage (mi sq) 83.5 0.50 2.25 0.28 0.72 3.75 Ratio to Middle Creek 1 0.006 0.027 0.003 0.009 0.04 Monitoring Monthly to bi-weekly water quality monitoring was performed at five locations (UTC-1, UTC-4, UTC-5, UTC-7, and UTC-10A) in the Utley Creek watershed (see Attachment A- 1) from July 2009 to the present. The monitoring data collected are provided in Attachment A- 2. The August 25, 2009 date was selected for model calibration since it occurred during a low flow period and field and laboratory monitoring data was collected on this date. 3 COPYRIGHT 2011 BY CH2M HILL, INC. ' COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Meteorology Temperature, cloud cover, and windspeed data was obtained for August 25, 2009 from the Raleigh -Durham International Airport meteorology station for use in the model. FIGURE 1 Results of the Utley Creek QUAL2E Calibration Run u u O 100 10 1 Estimated Flow in Utley Creek i vmJAA 0.1 �����\ctio\titi� 1�ti�ti�ti�ti ti�\ti�ti�\���ti�\ a�ti�`�h�ti�\� ��ti~\��ti�\ ��ti�`� a1\�oy��~�\�ti�ti�\� Model Calibration The model was set up using the information described above. The model was run in steady state mode for temperature, nutrients, and dissolved oxygen. The algal component was turned off since past experience has shown the model results to be less conservative if run with the algal simulation turned on. The estimated headwater and tributary flows were estimated based on the scaling flows using information in Table 3. The scaling factor for the Middle Creek flows at Thomas Mill Pond was determined to be 0.027 using the ratio of drainage areas. For August 25, 2009, the flow in Middle Creek was 18 cfs resulting in an estimated headwater flow for Utley Creek below Thomas Mill Pond of 0.48 cfs. Station UT-5 is at a location near the outlet of Thomas Mill Pond. The data from this location was used to develop the headwater characteristics for the calibration. Values for the headwater input are provided in Table 4. Monitoring has also been performed at a location approximately 1.1 miles downstream from Thomas Mill Pond identified as UTC-7. The data for UTC-7 was used to check the calibration of the model. 4 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Model parameters were, in general, set to acceptable literature values. The values for key parameters and inputs are provided in Table 5. The results of the calibration run are provided in Figure 2. The QUAT 7F, input file for this run is provided in Attachment A-3. Dissolved oxygen concentrations are above saturation in the headwaters due to algal blooms in Thomas Mill Pond. The model shows DO levels decreasing from these elevated levels and equilibrating by the time DO is measured at Station UTC-7. These results demonstrate that the model accurately predicts water quality in Utley Creek. TABLE 4 Headwater Inputs Parameter Value Comment Headwater Characteristics Flow (mgd) 2.56 Combination of WRF discharge and estimated watershed flow CBOD, 5-day (mg/L) 2 Assumed Dissolved Oxygen (mg/L) 11.0 From UTC-5 monitoring Ammonia-N (mg/L) 0.17 From UTC-5 monitoring Nitrate (mg/L) 1.31 From UTC-5 monitoring Nitrite (mg/L) 0.1 Assumed Total Phosphorus (mg/L) 0.68 From UTC-5 monitoring Orthophosphorus (mg/L) 0.53 Assumed TABLE 5 Values for Key QUAL2E Settings and Parameters Parameter Value Units Rearation model O'Connor -Dobbins Algal simulation No Channel Specification Trapezoidal Dispersion coefficient 60.0 Organic-N Hydrolysis 0.2 1/day Ammonia Oxidation rate 0.2 1/day BOD Deoxygenation Coefficient 0.23 1/day Nitrite Oxidation rate 10.0 1/day SOD uptake 0.1 gm/ft2/day 5 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE FIGURE 2 Results of the Utley Creek QUAL2E Calibration Run Utley Creek QUAL2E DO Calibration August 25, 2009 12 0 10 3 c: E 6 0 0 4 2 0 7 r 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 1.1 1.2 1.3 1.4 1.5 1.6 1.7 Distance below Thomas Millpond • DO Sat (mg/L) DO Sim (mg/L) —O—DOObs (mg/L) Uncertainty Analysis Based on the model results and an understanding of the Utley Creek system, it is expected that equilibration with the air and sediment would play the dominant role in controlling dissolved oxygen concentrations. The UNCAS component of the QUAL2E model was run to test out this assumption and to determine whether any given parameter can significantly skew model results. This analysis is performed using the lst Order analysis component. The results of this are shown in Table 6. These results show that DO levels are controlled by rearation. The most significant factors are the temperature of the discharge and the air pressure, both of which affect gas saturation. Varying these two factors, and therefore the amount of DO which can be dissolved in the water column, has a greater affect than decay of organic matter or the DO in the effluent. Since travel time is short between the discharge and the lake, there is limited time for decay of organic matter and the associated impacts to DO. The UNCAS component was also used to run a Monte Carlo analysis. This module ran 500 simulations, adjusting parameters to determine the range of possible DO concentrations. This sensitivity analysis is useful in situations where there is uncertainty associated with model inputs. The results show that lowest DO concentrations are expected to be at the end of the third reach and be in the range of 7.3 to 8.1 mg/L. The complete Monte Carlo analysis results are provided in Table 7.The 1st Order analysis and Monte Carlo runs support the conclusion that the discharge will have a minor effect on instream DO and that levels will remain well above the water quality standard. 6 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE TABLE 6 Sensitivity Analysis Results for Dissolved Oxygen Reach 1 Reach 2 Reach 3 Manning's n Variance 0.0001 0.0002 0.0002 Variance (%) 0.41% 0.73% 1.04% Wet Bulb Temperature Variance 0 0.0001 0.001 Variance (%) 0.09% 0.57% 4.42% Atmospheric Pressure Variance 0.0054 0.0062 0.0066 Variance (%) 28.63% 29.19% 30.40% Sediment Oxygen Demand Variance 0.0001 0.0007 0.0016 Variance (%) 0.34% 3.42% 7.37% Point Load Temperature Variance 0.0116 0.0135 0.0122 Variance (%) 61.44% 64.14% 55.64% Point Load DO Variance 0.0017 0.0003 0 Variance (%) 8.84% 1.59% 0.09% 7 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE TABLE 7 Monte Carlo Analysis Results for Dissolved Oxygen REACH 1 REACH 2 REACH 3 Simulation Mean 7.89 7.81 7.72 Bias 0.00 0.00 0.00 Minimum 7.56 7.46 7.30 Maximum 8.28 8.21 8.11 Range 0.72 0.74 0.82 Std Dev 0.14 0.15 0.15 Coefficient of Variance 0.02 0.02 0.02 Skew Coefficient 0.15 0.08 0.02 Scenario Evaluation The calibrated model was used to test the potential discharge of 6 mgd and 8 mgd at Location A and Location B to determine what impacts this discharge would have on nutrients and DO for an Utley Creek discharge. A baseline run was also done to evaluate predicted DO when no point source is included in Utley Creek. The environmental conditions are summer meteorology and low flow conditions. At the time the model was developed, the headwater flow of Utley Creek had not been determined. Therefore, a headwater flow of 0.01 cfs was used as a conservative estimate. It was not considered necessary to update these model runs based on the estimated 7Q10 flow of 0.24 cfs because of the effluent dominated nature of the discharge scenarios. The headwater DO was set to 4.0 mg/L to represent the potentially poor quality water being released from the Thomas Mill Pond. Other headwater conditions remained as in the model calibration run. As noted above, the actual flow from the pond is assumed to be minimal. Progress Energy originally developed the Greentree Reservoir for the purposes of wildlife management. The area can be flooded to a shallow depth through the use of a water control structure at the downstream end of the area. Progress Energy is proposing to use this area as a wetlands demonstration area (Progress Energy, 2011). The timeframe and specific operational strategies are undefined at this time. The QUAL2E model was modified to reflect the potential use of the area as a wetland/stream system by modifying the slope and Manning's n numbers in the middle reach of the model. For the scenario runs, the slope for the middle reach was changed from 0.0037 to 0.0001 and the Manning's n was changed from 0.04 to 0.15. This reduces the velocity in the middle reach by approximately an order of magnitude. 8 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Location A Scenarios The WRF discharge for the Location A scenarios is located at the first model element below Thomas Mill Pond. The information in Table 8 is based on the previously issued speculative limits for Harris Lake and was used to characterize the proposed discharge. The exception to this is the DO limit for both Phase I and Phase II were set to 6.0 mg/L. Since the effluent pipeline and new cascade have not been designed yet, it is not known whether a similar cascade system can be installed at the new location. The results for the baseline and 6 mgd and 8 mgd scenarios are shown in Figure 3. The QUAT .OF. input files for the baseline, 6 mgd, and 8 mgd runs are provided in Attachment A-4, A-5, and A-6, respectively. Location B Scenarios The WRF discharge for the Location B scenarios is located at the first model element below Greentree Reservoir. The information in Table 8 is based on the previously issued speculative limits for Harris Lake and was used to characterize the proposed discharge. As with the Location A scenarios, the DO limit was set to 6.0 mg/L. The results for the baseline and 6 mgd and 8 mgd scenarios are shown in Figure 4. The QUAT .OF. input files for the 6 mgd and 8 mgd runs are provided in Attachment A-7 and A-8, respectively. TABLE 8 Holly Springs WRF Discharge Characteristics Parameter Phase I Phase II Flow (mgd) 6.0 8.0 BOD, 5-day (mg/L) 5.0 5.0 Dissolved Oxygen (mg/L) 6.0 6.0 Ammonia-N (mg/L) 1.0 1.0 Total N (mg/L) 5.0 5.0 Nitrate (mg/L) 3.9 3.9 Nitrite (mg/L) 0.1 0.1 Total Phosphorus (mg/L) 0.5 0.5 Orthophosphorus (mg/L) 0.27 0.27 9 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE FIGURE 3 Results of the Utley Creek QUAL2E Location A Allocation Run Utley Creek QUAL2E DO Location A Scenario Comparison 9 8.5 Discharge Location 8 7.5 00 E 7 0 O 6.5 6 5.5 5 • 0 0.1 0.2 0.3 0.4 0.S 0.6 0.7 0.8 0.9 1 1.1 1.2 1.3 L4 1.5 1.6 1.7 Distance below Thomas Millpond (miles) - Baseline - 6mgd - - 8mgd FIGURE 4 Results of the Utley Creek QUAL2E Location B Allocation Run 0 8.5 S 7.5 E7 O 0 6.5 6 5.5 5 Utley Creek QUAL2E DO Location B Scenario Comparison Discharge Location f 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 1.1 1.2 1.3 1.4 1.5 1.6 1.7 Distance below Thomas Millpond (miles) 6mgd - - 8mgd - Baseline 10 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE The baseline run shows a consistent DO level near 7.4 mg/L for the sections above and below Greentree Reservoir, approximately 0.1 mg/L lower than saturation. A drop in DO to approximately 6.5 is seen in the middle reach due to low velocities in the simulated wetland/stream system of Greentree Reservoir. Under the baseline condition, the DO levels never reach saturation since SOD removes a fraction of the available DO. Under the scenario runs, virtually all of the flow is from the WRF. The instream DO concentration is dominated by rearation associated with the additional flow from the WRF. The same pattern of a jump in DO due to rearation from the increased flow, followed by gradually decreasing DO is seen for both locations. The main difference seen between the two scenarios is that location of the DO jump is further downstream for the Location B scenarios as would be expected. The Location A scenarios maintain a slightly higher DO in the Greentree Reservoir section whereas the Location B scenarios result in a slightly higher DO at the end of the simulated section at the 220' elevation. Conclusions The model results demonstrate that the proposed discharge at either location will not adversely impact and can potentially improve water quality conditions in the lower section of Utley Creek. Flow from the WRF currently enters Thomas Mill Pond which is shallow and subject to algal blooms. The flow leaving theyond is often of marg.a, i c uality. Both discharge locations maintain DO levels above the water quality standard. Introduction of the effluent from the WRF will provide a steady baseflow of high quality water in the ower section o Utley Creek. Ilk u derstood that there is some uncertainty regarding the o eratin re a that will be used b Pro er for Greentree Rese at long eriods of deep impoun ent ma result in . .e_ • uali co ditions similar to what has occurre. m omas ill and if the discharge is at Location ocation A. Location B below Greentree '--Reservoir eviates s concern. An evaluation of a discharge to Harris Lake was documented in the report Evaluation of Potential Holly Springs Discharge Scenarios (CH2M HILL, 2009). Speculative limits for a lake discharge were provided by DWQ on February 23rd, 2010 (DWQ, 2010). The modeling presented in this technical memorandum demonstrates that the speculative limits are also appropriate for a discharge to Utley Creek. Since the effluent pipeline and new cascade have not been designed yet, it is not known whether a similar cascade system can be installed at the new location. Based on the modeling results, especially the slope of DO decline and the short distance to Harris Lake, it is our professional opinion that an effluent DO of 6 mg/L would also protect water quality in the creek. The limits shown in Table 9 are therefore requested from DWQ. 11 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE TABLE 9 Requested Holly Springs WRF Speculative Limits Parameter Monthly Average Weekly Average Flow (mgd) 6.0/8.0 BOD, 5-day (mg/L) 5.0 7.5 Ammonia-N (mg/L) 1.0 3.0 Total Suspended Solids (mg/L) 30.0 45.0 Dissolved Oxygen (mg/L) 6.01 6.01 pH 6.0 — 9.0 6.0 — 9.0 Total Residual Chlorine (mg/L) 28.02 28.02 Total N (mg/L) 5.0 5.0 Total Phosphorus (mg/L) 0.5 0.5 Orthophosphorus (mg/L) 0.27 0.27 'Minimum daily average 2 Daily maximum References CH2M HILL. 2009. Evaluation of Potential Holly Springs Discharge Scenarios. Raleigh, NC. DWQ. 2010. Speculative Limits, Town of Holly Springs WWTP. North Carolina Division of Water Quality. February 23, 2010. Personal Communication with USGS. 2011. Meeting with Town of Holly Springs, CH2M Hill, and Curtis Weaver/USGS and Jeanne Robbins/ USGS on May 9, 2011. Progress Energy. 2011. Letter to the Town of Holly Springs Regarding Plans for Utley Creek and Greentree Reservoir. US EPA. 1987. The Enhanced Stream Water Quality Models QUAL2E and QUAL2E-UNCAS: Documentation and User Manual. U.S. Environmental Protection Agency, Office of Research and Development. Athens, GA. USGS. 2005. DFLOW 3.1 User's Guide. U.S. Geological Survey. 12 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL Attachment A-1. Utley Creek Monitoring and Proposed Discharge Location Area Map Utley Creek Monitoring and Proposed Discharge Locations 0 0.150.3 0.6 0.9 1.2 Miles 14 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL Belnick, Tom From: BiII.Kreutzberger@CH2M.com Sent: Tuesday, June 21, 2011 2:11 PM To: Belnick, Tom; Poupart, Jeff; Stecker, Kathy Cc: Wakild, Chuck; Clark, Alan; Matthews, Matt; stephanie.sudano@Hollyspringsnc.us; Klaus.Albertin@CH2M.com; Ruth.Swanek@CH2M.com Subject: Request for Speculative Permit Limits for the Town of Holly Springs Attachments: Utley Ck QUAL2E TM-6-21-2011 Final.pdf Dear Tom, Jeff and Kathy —The purpose of this email is to request speculative permit limits for the Town of Holly Springs to discharge to Utley Creek below Greentree Reservoir (Location B in the attached Technical Memorandum). In reviewing information for the Town's draft EA, we determined that additional analysis was necessary to actually evaluate a discharge into the White Oak arm of Harris Lake. The prior alternative developed for this stopped short of the lake — primarily to avoid wetland impacts. While the team working on the EA is evaluating a route and impacts to discharge directly to the lake, we thought it would also be appropriate to request speculative limits to the Creek below Greentree Reservoir since we already had modeling information that could be adapted for this location. If acceptable — this location will have fewer wetland impacts than discharging directly to the lake. The attached TM includes a description of Utley Creek and development of the model. It includes some modifications to the model to simulate the wetland like nature of the Greentree Reservoir operated in a partially submerged state — as being planned by Progress Energy. The model includes discharge scenarios below Thomas Mill Pond (Location A) and below Greentree Reservoir (Location B). It is this latter location that we are requesting speculative limits for based on the past concerns of water quality problems in impoundments and the uncertainty in how Progress plans to operate the Greentree Reservoir. We believe this analysis is relatively straightforward. If you have any questions or comments, please do not hesitate to contact me so that we can get information to address these as quickly as possible. Thanks Bill Kreutzberger Bill Kreutzberger I CH2M HILL! Charlotte Office; Direct Phone (704) 543-3269 (Mobile (/04)904-5918 IEmail - bill.kreutzbergerC@ch2m.com 1 '. 1�foIrIriea-, PITMI Filr Akto 63011, C/usif TECHNICAL MEMORANDUM CU412MHILL Evaluation of Proposed Utley Creek Discharge PREPARED FOR: NC Division of Water Quality PREPARED BY: Klaus Albertin\CH2M HILL COPIES: DATE: Background Stephanie Sudano\Town of Holly Springs Bil - tzberger\CH2M HILL The Town of Holly Springs ("Town') is evaluating wastewater treatment and disposal options to meet their growing demands. The Town currently discharges effluent from their water reclamation facility (WRF) to the headwaters of Utley Creek, a tributary to the White Oak Creek arm of Harris Lake. The Town has received speculative limits for a discharge directly to the White Oak Creek arm of Harris Lake. The Town is interesting in exploring the potential for an alternative discharge location to Utley Creek below Thomas Mill Pond. Discharging to Utley Creek will result in a shorter effluent line, less habitat disturbance, lower greenhouse gas emissions, and resulting lower capital and operating costs. This alternative has already been evaluated in a draft Environmental Assessment (EA); however review of this EA/alternative by the North Carolina Division of Water Quality (DWQ) and other state/federal agencies cannot proceed until speculative limits have been issued for this discharge location. This memo describes the approach used to provide technical support for a decision regarding speculative effluent limits. Approach The proposed WRF discharge location is directly below Thomas Millpond and approximately 1.7 miles from the lake at its current level of 220' MSL and approximately 1.1 miles from the 240' MSL contour if the lake is raised to support expansion of the Shearon Harris Nuclear Power facilities (see Attachment A-1). The QUAL2E-UNCAS model was used to evaluate the potential impacts to dissolved oxygen (DO) concentrations as a result of the proposed discharge. QUAL2E-UNCAS is steady state stream water quality model that is widely applied to support this type of evaluation (US EPA, 1987). Model Setup The model requires stream geometry, meteorological inputs, inflow information, instream observations, and point source characteristics to predict instream water quality. The QUAL2E model was setup to represent Utley Creek for a calibration period and for evaluating the proposed discharge during critical conditions; 7-day, 10-year low flow (7Q10 flow) and summer temperatures. COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Stream Visit Utley Creek is regularly visited as part of an ongoing monitoring program; however, a more detailed field examination was performed on February 18th, 2011. The stream was walked from the proposed discharge location below Thomas Millpond to its confluence with the White Oak Arm of Harris Lake. Estimates of geometry were determined at regular intervals and at areas where the stream characteristics changed significantly. The creek was highly variable with sections changing from wide, straight, shallow areas to meandering, narrower, pooled sections. Based on the field observations, the model was split into three distinct reaches. The characteristics as generalized in the model are provided in Tables 1 and 2. TABLE 1 Utley Creek Reach Characteristics Reach Segment Length (mi) Width (ft) Depth (ft) Type Thomas Millpond to 0.8 12 1 Relatively wide and straight, 1st Tributary occasional impedances from vegetation or geology — moderate Manning's n 1st Tributary to 2nd 0.5 19 1 - 2 Meandering with a few deeper Tributary pools— higher Manning's n 2nd Tributary to Harris Lake 0.4 15 1 Meandering but wider with fewer pools, backwater near confluence with Harris Lake — moderate Manning's n TABLE 2 Utley Creek Reach Characteristics Reach Segment Top Elevation (ft) Bottom Elevation Slope (ft/ft) Manning's (ft) Thomas Millpond to 262 1st Tributary 1s` Tributary to 2nd 248 Tributary 2nd Tributary to 238 Harris Lake 248 0.0065 0.035 238 0.0037 0.040 220 0.0043 0.035 2 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Inflow Utley Creek is not monitored for flow. The current NPDES permit for the Utley Creek WWTP is based on a 7Q10 value of 0.11 cfs. In researching this value, it was based on an analysis by USGS that used three stations in the Raleigh area and the actual rate identified by USGS was 0.11 cfs/mil (Personal Communication with USGS, 2011). This rate was used to estimate a 7Q10 flow value for the new discharge location of 0.24 cfs based on the drainage area of 2.25 mil. Scaling of flows from the USGS gage on Middle Creek near Clayton (USGS 02088000) was used to develop a surrogate flow timeseries for Utley Creek for use in model calibration. The Middle Creek watershed at this gage was identified as having similar characteristics as the Utley Creek watershed although the Middle Creek flows are somewhat augmented by discharges. The Utley Creek flows were estimated by scaling the Middle Creek flows by the ratio of the drainage areas. The relevant information for this approach is provided in Table 3. The uncertainty analysis component (UNCAS) will be used to provide the estimate of the impacts that these assumptions will have on model results. The Middle Creek gage data was used to determine an appropriate time period for selecting data from the monitoring program for model calibration. Review of the gage data indicated that the lowest flow during the water quality monitoring period for Utley Creek occurred in August 2009 as shown in Figure 1. As described in the next section, dates when monitoring was performed were identified to select a specific calibration date. TABLE 3 Drainage Area Ratios Used for Calibration Flow Estimates of Utley Creek Middle Ck Utley Creek Utley Creek Trib Trib Total Direct drainage Direct drainage 1 2 below TMP above TMP Drainage (ac) 53,440 319.6 1437.7 178.6 463.6 2399.5 Drainage (mi sq) 83.5 0.50 2.25 0.28 0.72 3.75 Ratio to Middle Creek 1 0.006 0.027 0.003 0.009 0.04 Monitoring Monthly to bi-weekly water quality monitoring was performed at five locations in the Utley Creek watershed (see Attachment A- 1) from July 2009 to the present. The monitoring data collected are provided in Attachment A- 2. The August 25, 2009 date was selected for model calibration since it occurred during a low flow period and field and laboratory monitoring data was collected on this date. 3 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Meteorology Temperature, cloud cover, and windspeed data was obtained for August 25, 2009 from the Raleigh -Durham International Airport meteorology station for use in the model. FIGURE 1 Results of the Utley Creek QUAL2E Calibration Run V u 0 100 10 Estimated Flow in Utley Creek 0.1 oc) 00 000 oc) cf) oc) 6%, ONO 01O 01O OHO O,• O, O, O,• O O,O OHO O,O ftsv 41, Model Calibration The model was set up using the information described above. The model was run in steady state mode for temperature, nutrients, and dissolved oxygen. The algal component was turned off since past ex erience has shown th odel results to be less conservative iTrun with the algal simulation turned on. The estimate headwater and ributary f o weir" - estimated based on the scaling flows using information in Table 3. The scaling factor for the Middle Creek flows at Thomas Millpond was determined to be 0.027 using the ratio of drainage areas. For August 25, 2009, the flow in Middle Creek was 18 cfs resulting in an estimated headwater flow for Utley creek below Thomas Millpond of 0.48 cfs. Station UT-5 is at a location near the outlet of Thomas Millpond. The data from this location was used to develop the headwater characteristics for the calibration. Values for the headwater input are provided in Table 4. Monitoring has also been performed at a location approximately 1.1 miles downstream from Thomas Millpond identified as UTC-7. The data for UTC-7 was used to check the calibration of the model. 4 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Model parameters were, in general, set to acceptable literature values. The values for key parameters and inputs are provided in Table 5. The results of the calibration run are provided in Figure 2. The QUAL2E input file for this run is provided in Attachment A-3. Dissolved oxygen concentrations are above saturation in the headwaters due to algal blooms in Thomas Millpond. The model shows DO levels decreasing from these elevated levels and equilibrating by the time DO is measured at Station UTC-7. These results demonstrate that the model accurately predicts water quality in Utley Creek. TABLE 4 Headwater Inputs Parameter Value Comment Headwater Characteristics Flow (mgd) 2.56 Combination of WRF discharge and estimated watershed flow CBOD, 5-day (mg/L) 2 Assumed Dissolved Oxygen (mg/L) 11.0 From UTC-5 monitoring Ammonia-N (mg/L) 0.17 From UTC-5 monitoring Nitrate (mg/L) 1.31 From UTC-5 monitoring Nitrite (mg/L) 0.1 Assumed Total Phosphorus (mg/L) 0.68 From UTC-5 monitoring Orthophosphorus (mg/L) 0.53 Assumed TABLE 5 Values for Key QUAL2E Settings and Parameters Parameter Value Units Re -aeration model O'Connor -Dobbins Algal simulation No Channel Specification Trapezoidal Dispersion coefficient 60.0 Organic-N Hydrolysis 0.2 1/day Ammonia Oxidation rate 0.2 1/day BOD Deoxygenation Coefficient 0.23 1/day Nitrite Oxidation rate 10.0 1/day SOD uptake 0.1 gm/ft2/day 5 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE FIGURE 2 Results of the Utley Creek QUAL2E Calibration Run 12 Utley Creek QUAL2E DO Calibration August 25, 2009 10 • E 6- O a 4 2 0 7 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 1.1 1.2 1.3 l.4 1.5 1.6 1.7 Distance below Thomas Millpond --a—DOSat (mg/L) --El—DO Sim (mg/L} --BB—DOObs (mg/L) Uncertainty Analysis Based on the model results and an understanding of the Utley Creek system, it is expected that equilibration with the air and sediment would play the dominant role in controlling dissolved oxygen concentrations. The UNCAS component of the QUAL2E model was run to test out this assumption and to determine whether any given parameter can significantly skew model results. This analysis is performed using the 1st Order analysis component. The results of this are shown in Table 6. These results show that DO levels are controlled by rearation. The most significant factors are the temperature of the discharge and the air pressure, both of which affect gas saturation. Varying these two factors, and therefore the amount of DO which can be dissolved in the water column, has a greater affect than decay of organic matter or the DO in the effluent. Since travel time is short between the discharge and the lake, there is limited time for decay of organic matter and the associated impacts to DO. The UNCAS component was also used to run a Monte Carlo analysis. This module ran 500 simulations, adjusting parameters to determine the range of possible DO concentrations. This sensitivity analysis is useful in situations where there is uncertainty associated with model inputs. The results show that lowest DO concentrations are expected to be at the end of the third reach and be in the range of 7.3 to 8.1 mg/L. The complete Monte Carlo analysis results are provided in Table 7.The 1st Order analysis and Monte Carlo runs support the conclusion that the discharge will have a minor effect on instream DO and that levels will remain well above the water quality standard. 6 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE TABLE 6 Sensitivity Analysis Results for Dissolved Oxygen Reach 1 Reach 2 Reach 3 Manning's n Variance 0.0001 0.0002 0.0002 Variance (%) 0.41% 0.73% 1.04% Wet Bulb Temperature Variance 0 0.0001 0.001 Variance (%) 0.09% 0.57% 4.42% Atmospheric Pressure Variance 0.0054 0.0062 0.0066 Variance (%) 28.63% 29.19% 30.40% Sediment Oxygen Demand Variance 0.0001 0.0007 0.0016 Variance (%) 0.34% 3.42% 7.37% Point Load Temperature Variance 0.0116 0.0135 0.0122 Variance (%) 61.44% 64.14% 55.64% Point Load DO Variance 0.0017 0.0003 0 Variance (%) 8.84% 1.59% 0.09% 7 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE TABLE 7 Monte Carlo Analysis Results for Dissolved Oxygen REACH 1 REACH 2 REACH 3 Simulation Mean 7.89 7.81 7.72 Bias 0.00 0.00 0.00 Minimum 7.56 7.46 7.30 Maximum 8.28 8.21 8.11 Range 0.72 0.74 0.82 Std Dev 0.14 0.15 0.15 Coefficient of Variance 0.02 0.02 0.02 Skew Coefficient 0.15 0.08 0.02 Scenario Evaluation The calibrated model was used to test the potential discharge of 6 mgd and 8 mgd below Thomas Millpond using the speculative limits for the Harris Lake discharge to determine what impacts this discharge would have on nutrients and DO for an Utley Creek discharge. A baseline run was also done to evaluate predicted DO when no point source is included in Utley Creek. The environmental conditions are summer meteorology and low flow conditions. At the time the model was developed, the headwater flow of Utley Creek had not been determined. Therefore, a headwater flow of 0.01 cfs was used as a conservative estimate. It was not considered necessary to update these model runs based on the estimated 7Q10 flow of 0.24 cfs because of the effluent dominated nature of the discharge scenarios. The headwater DO was set to 4.0 mg/L to represent the potentially poor quality water being released from the Millpond. Other headwater conditions remained as in the model calibration run. As noted above, the actual flow from the pond is assumed to be minimal. The WRF discharge for the scenarios is located at the first segment below Thomas Millpond. The information in Table 8 was used to characterize the proposed discharge. The results for the baseline and 6 mgd and 8 mgd scenarios are shown in Figure 3. The QUAL2E input files for the, baseline, 6 mgd, and 8 mgd runs are provided in Attachment A-4, A-5, and A-6, respectively. The discharge parameters shown in Table 8 are based on the previously issued speculative limits for Harris Lake. 8 COPYRIGHT 2011 BY CH2M HILL INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE TABLE 8 Holly Springs WRF Discharge Characteristics Parameter Phase I Phase II Flow (mgd) BOD, 5-day (mg/L) Dissolved Oxygen (mg/L) Ammonia-N (mg/L) Total N (mg/L) Nitrate (mg/L) Nitrite (mg/L) Total Phosphorus (mg/L) Orthophosphorus (mg/L) 6.0 8.0 5.0 5.0 7.0 7.0 1.0 1.0 5.0 5.0 3.9 3.9 0.1 0.1 0.5 0.5 0.27 0.27 FIGURE 3 Results of the Utley Creek QUAL2E Allocation Run 8.5 Utley Creek QUAL2E DO Scenario Comparison 7.5 ▪ ac E 7 O • 6.5 6 5.5 5 . V , T T 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 1.1 1.2 1.3 1.4 1.5 1.6 1.7 Distance below Thomas Millpond - Baseline �,_.. 6mgd - _- 8mgd 9 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE The baseline run shows a consistent DO level near 7.4 mg/L, approximately 0.1 mg/L lower than saturation. Under the baseline condition, the DO levels never reach saturation since SOD removes a fraction of the available DO. Under the scenario runs, all of the flow is from the WRF. The initial instream DO is controlled by the DO concentration of effluent but is quickly dominated by rearation associated with the additional flow. The same pattern of gradually decreasing DO is seen. The DO level remains slightly, approximately 0.25 mg/L, below saturation for both the scenarios. Conclusions The model results demonstrate that the proposed discharge will not adversely impact and can potentially improve water quality conditions in the lower section of Utley Creek below Thomas Millpond. Flow from the WRF currentl ent omas Mill and which is shallow and subject to algal blooms. a eaving the pond is often of marginal quality. Introduction of the effluent from the WRF will provide a steady baseflow of high quality water in Utley Creek below Thomas Millpond. An evaluation of a discharge directly to Harris Lake was documented in the report Evaluation of Potential Holly Springs Discharge Scenarios (CH2M HILL, 2009). Speculative limits for a lake discharge were provided by DWQ on February 23rd, 2010 (DWQ, 2010). The modeling presented in this technical memorandum demonstrate that the speculative limits are also appropriate for a discharge to Utley Creek. The limits shown in Table 9 are therefore requested from DWQ. The effluent DO level of 7 mg/ L provides a good margin of protection for the creek and can be achieved by the current discharge cascade system. Since the effluent pipeline and new cascade have not been designed yet, it is not known whether a similar cascade system can be installed at the new location. Based on the modeling results, especially the slope of DO decline and the short distance to Harris Lake, it is our professional opinion that an effluent DO of 6 mg/L would also protect water quality in the creek. After preliminary design of facilities, the Town of Holly Springs may request that this effluent limit be re-evaluated. 10 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE TABLE 9 Requested Holly Springs WRF Speculative Limits Parameter Monthly Average Flow (mgd) 6.0/8.0 BOD, 5-day (mg/L) 5.0 Ammonia-N (mg/L) 1.0 Total Suspended Solids (mg/L) 30.0 Dissolved Oxygen (mg/L) 7.01 pH 6.0 — 9.0 Total Residual Chlorine (mg/L) 28.02 Total N (mg/L) 5.0 Total Phosphorus (mg/L) 0.5 Orthophosphorus (mg/L) 0.27 'Minimum daily average 2 Daily maximum References Weekly Average 7.5 3.0 45.0 7.01 6.0 — 9.0 28.02 5. 0.5 0.27 CH2M HILL. 2009. Evaluation of Potential Holly Springs Discharge Scenarios. Raleigh, NC. DWQ. 2010. Speculative Limits, Town of Holly Springs VWVrf P. North Carolina Division of Water Quality. February 23, 2010. Personal Communication with USGS. 2011. Meeting with Town of Holly Springs, CH2M Hill, and Curtis Weaver/USGS and Jeanne Robbins/USGS on May 9, 2011. US EPA. 1987. The Enhanced Stream Water Quality Models QUAL2E and QUAL2E-UNCAS: Documentation and User Manual. U.S. Environmental Protection Agency, Office of Research and Development. Athens, GA. USGS. 2005. DFLOW 3.1 User's Guide. U.S. Geological Survey. �77 re aziit 11 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Attachment A-1 Map of Utley Creek Proposed Discharge and Existing Monitoring Locations 12 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL Utley_Creek I larris Lake 0 0.2 0.4 — _ __. ■ Attachment A-1. Utley Creek Discharge Location Area Map 0.8 1.2 1.6 Miles 13 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL Attachment A-2 Utley Creek Monitoring Data 14 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL • EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Insert pdf here. 15 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Attachment A-3 Utley Creek Calibration Input File 16 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL r EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE TITLE01 TITLE02 TITLE03 NO TITLE04 NO TITLE05 NO TITLE06 YES TITLE07 YES TITLE08 NO TITLE09 YES TITLE10 TITLE11 YES TITLE12 TITLE13 YES TITLE14 NO TITLE15 NO ENDTITLE LIST DATA INPUT WRITE OPTIONAL SUMMARY NO FLOW AUGMENTATION STEADY STATE TRAPEZOIDAL X-SECTIONS NO PRINT LCD/SOLAR DATA PLOT DO AND BOD FIXED DNSTM COND (YES=1)= INPUT METRIC (YES=1) = NUMBER OF REACHES NUM OF HEADWATERS = TIME STEP (HOURS) = MAXIMUM ITERATIONS = LATITUDE OF BASIN (DEG) = STANDARD MERIDIAN (DEG) = EVAP. COEFF. (AE) _ ELEV. OF BASIN (ELEV) _ ENDATA1 O UPTAKE BY NH3 OXID(MG 0/MG N)= 3.43 O PROD BY ALGAE (MG 0/MG A) = 1.6 N CONTENT OF ALGAE (MG N/MG A) = 0.085 ALG MAX SPEC GROWTH RATE(1/DAY)= 2.5 N HALF SATURATION CONST (MG/L) = 0.2 LIN ALG SHADE CO (1/H-UGCHA/L)=0.00075 LIGHT FUNCTION OPTION (LFNOPT) = 1.0 DAILY AVERAGING OPTION (LAVOPT)= 2.0 NUMBER OF DAYLIGHT HOURS (DLH) = 14.0 2.0 0.44 UTLEY CK CALIBRATION WHITE OAK SUBBASIN CONSERVATIVE MINERAL I IN CONSERVATIVE MINERAL II IN CONSERVATIVE MINERAL III IN TEMPERATURE BIOCHEMICAL OXYGEN DEMAND ALGAE AS CHL-A IN UG/L PHOSPHORUS CYCLE AS P IN MG/L (ORGANIC-P, DISSOLVED-P) NITROGEN CYCLE AS N IN MG/L (ORGANIC-N, AMMONIA-N, NITRITE-N, NITRATE-N) DISSOLVED OXYGEN IN MG/L FECAL COLIFORMS IN NO./100 ML ARBITRARY NON -CONSERVATIVE 0.0 0.0 3.0 1.0 1.0 30.0 35.6 75.0 0.00103 240.0 ALGY GROWTH CALC OPTION(LGROPT)= ALG/TEMP SOLR RAD FACTOR(TFACT)= ENDATA1A ENDATA1B STREAM REACH STREAM REACH STREAM REACH ENDATA2 ENDATA3 FLAG FIELD RCH= 1.0 4 FLAG FIELD RCH= 2.0 5 FLAG FIELD RCH= 3.0 8 1.ORCH=Below TMP 2.ORCH=Below Trib 1 3.ORCH=Below Trib 2 5D-ULT BOD CONV K COEF = OUTPUT METRIC (YES=1) = NUMBER OF JUNCTIONS = NUMBER OF POINT LOADS = LNTH COMP ELEMENT (DX)= TIME INC. FOR RPT2 (HRS)= LONGITUDE OF BASIN (DEG)= DAY OF YEAR START TIME = EVAP. COEFF. (BE) _ DUST ATTENUATION COEF. = O UPTAKE BY NO2 OXID(MG 0/MG N)= O UPTAKE BY ALGAE (MG 0/MG A) = P CONTENT OF ALGAE (MG P/MG A) = ALGAE RESPIRATION RATE (1/DAY) = P HALF SATURATION CONST (MG/L)= NLIN SHADE (1/H-(UGCHA/L)**2/3)= LIGHT SATURATION COEF (INT/MIN)= TOTAL DAILY SOLAR RADTN (INT) = TOTAL DAILY SOLAR RADTN (INT) = ALGAL PREF FOR NH3-N (PREFN) = NITRIFICATION INHIBITION COEF = FROM FROM FROM 1 6 2 2 2 6 2 2 2 2 6 2 2 2 2 2 5 1.7 1.3 0.8 TO TO TO 17 0.23 0.0 0.0 3.0 0.1 1.0 78.9 237.0 0.00016 0.06 1.14 2.0 0.014 0.05 0.04 0.0 0.11 0.92 1300.0 0.9 10.0 1.3 0.8 0.0 COPYRIGHT 2011 BY CH2M HELL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE ENDATA4 HYDRAULICS RCH= 1.0 60.0 2.0 2.0 15.0 0.0065 0.035 HYDRAULICS RCH= 2.0 60.0 2.0 2.0 10.0 0.0037 0.040 HYDRAULICS RCH= 3.0 60.0 2.0 2.0 18.0 0.0043 0.035 ENDATA5 TEMP/LCD RCH= 1.0 240.0 0.06 0.3 78.0 74.0 30.1 4.4 TEMP/LCD RCH= 2.0 240.0 0.06 0.3 78.0 74.0 30.1 4.4 TEMP/LCD RCH= 3.0 240.0 0.06 0.3 78.0 74.0 30.1 4.4 ENDATA5A REACT COEF RCH= 1.0 0.23 0.0 0.1 3.0 0.0 0.0 0.0 REACT COEF RCH= 2.0 0.23 0.0 0.1 3.0 0.0 0.0 0.0 REACT COEF RCH= 3.0 0.23 0.0 0.1 3.0 0.0 0.0 0.0 ENDATA6 N AND P COEF RCH= 1.0 0.2 0.0 0.2 0.0 10.0 0.0 0.0 0.0 N AND P COEF RCH= 2.0 0.2 0.0 0.2 0.0 10.0 0.0 0.0 0.0 N AND P COEF RCH= 3.0 0.2 0.0 0.2 0.0 10.0 0.0 0.0 0.0 ENDATA6A ALG/OTHER COEF RCH= 1.0 10.0 0.6 0.04 0.0 0.0 0.0 0.0 ALG/OTHER COEF RCH= 2.0 10.0 0.6 0.04 0.0 0.0 0.0 0.0 ALG/OTHER COEF RCH= 3.0 10.0 0.6 0.04 0.0 0.0 0.0 0.0 ENDATA6B INITIAL COND-1 RCH= 1.0 80.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-1 RCH= 2.0 78.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-1 RCH= 3.0 78.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 ENDATA7 INITIAL COND-2 RCH= 1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-2 RCH= 2.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-2 RCH= 3.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 ENDATA7A INCR INFLOW-1 RCH= 1.0 0.0 70.0 0.0 0.0 0.0 0.0 0.0 0.00.E+00 INCR INFLOW-1 RCH= 2.0 0.11 80.0 8.0 1.0 0.0 0.0 0.0 0.00.E+00 INCR INFLOW-1 RCH= 3.0 0.0 70.0 0.0 0.0 0.0 0.0 0.0 0.00.E+00 ENDATA8 INCR INFLOW-2 RCH= 1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INCR INFLOW-2 RCH= 2.0 0.0 0.2 0.02 0.2 0.0 0.4 0.06 INCR INFLOW-2 RCH= 3.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 ENDATA8A ENDATA9 HEADWTR-1 HDW= 1.0ThomasMP 2.25 80.6 11.0 5.0 0.0 0.0 0.0 ENDATA10 HEADWTR-2 HDW= 1.0 0.00.E+00 17.8 1.5 0.29 0.10 2.98 0.7 0.69 ENDATA10A POINTLD-1 PTL= 1.0HS WRF 0.0 0.00 80.0 8.0 0.0 0.0 0.0 0.0 POINTLD-1 PTL= 2.0Trib1 0.0 0.06 80.0 8.0 1.0 0.0 0.0 0.0 POINTLD-1 PTL= 3.0Trib2 0.0 0.16 80.0 8.0 1.0 0.0 0.0 0.0 ENDATA11 POINTLD-2 PTL= 1.0 0.00.E+00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 POINTLD-2 PTL= 2.0 0.00.E+00 0.0 1.15 0.08 0.05 0.2 0.4 0.06 POINTLD-2 PTL= 3.0 0.00.E+00 0.0 1.15 0.08 0.05 0.2 0.4 0.06 ENDATA11A ENDATA12 DOWNSTREAM BOUNDARY-1 70.0 0.0 0.0 0.0 0.0 0.0 0.00.0E+00 ENDATA13 ENDATA13A BEGIN RCH 1 18 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL PLOT RCH 1 2 3 EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE 19 COPYRIGHT 2011 BY CH2M H111, INC. • COMPANY CONFIDENTIAL r EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Attachment A-4 Utley Creek Baseline Scenario Input File 20 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE TITLE01 TITLE02 TITLE03 NO TITLE04 NO TITLE05 NO TITLE06 YES TITLE07 YES TITLE08 NO TITLE09 YES TITLE10 TITLE11 YES TITLE12 TITLE13 YES TITLE14 NO TITLE15 NO ENDTITLE LIST DATA INPUT WRITE OPTIONAL SUMMARY NO FLOW AUGMENTATION STEADY STATE TRAPEZOIDAL X-SECTIONS NO PRINT LCD/SOLAR DATA PLOT DO AND BOD FIXED DNSTM COND (YES=1)= UTLEY CK BASELINE WHITE OAK SUBBASIN CONSERVATIVE MINERAL I IN CONSERVATIVE MINERAL II IN CONSERVATIVE MINERAL III IN TEMPERATURE BIOCHEMICAL OXYGEN DEMAND ALGAE AS CHL-A IN UG/L PHOSPHORUS CYCLE AS P IN MG/L (ORGANIC-P, DISSOLVED-P) NITROGEN CYCLE AS N IN MG/L (ORGANIC-N, AMMONIA-N, NITRITE-N, NITRATE-N) DISSOLVED OXYGEN IN MG/L FECAL COLIFORMS IN NO./100 ML ARBITRARY NON -CONSERVATIVE 0.0 INPUT METRIC (YES=1) = 0.0 NUMBER OF REACHES = 3.0 NUM OF HEADWATERS = 1.0 TIME STEP (HOURS) = 1.0 MAXIMUM ITERATIONS = 30.0 LATITUDE OF BASIN (DEG) = 35.6 STANDARD MERIDIAN (DEG) = 75.0 EVAP. COEFF. (AE) = 0.00103 ELEV. OF BASIN (ELEV) = 240.0 ENDATA1 O UPTAKE BY NH3 OXID(MG 0/MG N)= 3.43 O PROD BY ALGAE (MG 0/MG A) = 1.6 N CONTENT OF ALGAE (MG N/MG A) = 0.085 ALG MAX SPEC GROWTH RATE(1/DAY)= 2.5 N HALF SATURATION CONST (MG/L) = 0.2 LIN ALG SHADE CO (1/H-UGCHA/L)=0.00075 LIGHT FUNCTION OPTION (LFNOPT) = DAILY AVERAGING OPTION (LAVOPT)= NUMBER OF DAYLIGHT HOURS (DLH) = ALGY GROWTH CALC OPTION(LGROPT)= ALG/TEMP SOLR RAD FACTOR(TFACT)= ENDATA1A ENDATA1B STREAM REACH STREAM REACH STREAM REACH ENDATA2 ENDATA3 FLAG FIELD RCH= 1.0 4 FLAG FIELD RCH= 2.0 5 FLAG FIELD RCH= 3.0 8 1.0 2.0 14.0 2.0 0.44 1.ORCH=Below TMP 2.ORCH=Below Trib 1 3.ORCH=Below Trib 2 5D-ULT BOD CONV K COEF = OUTPUT METRIC (YES=1) = NUMBER OF JUNCTIONS = NUMBER OF POINT LOADS = LNTH COMP ELEMENT (DX)= TIME INC. FOR RPT2 (HRS)= LONGITUDE OF BASIN (DEG)= DAY OF YEAR START TIME = EVAP. COEFF. (BE) = DUST ATTENUATION COEF. _ O UPTAKE BY NO2 OXID(MG 0/MG N)= O UPTAKE BY ALGAE (MG 0/MG A) = P CONTENT OF ALGAE (MG P/MG A) = ALGAE RESPIRATION RATE (1/DAY) = P HALF SATURATION CONST (MG/L)= NLIN SHADE (1/H-(UGCHA/L)**2/3)= LIGHT SATURATION COEF (INT/MIN)= TOTAL DAILY SOLAR RADTN (INT) = TOTAL DAILY SOLAR RADTN (INT) = ALGAL PREF FOR NH3-N (PREFN) = NITRIFICATION INHIBITION COEF = FROM FROM FROM 1 6 2 2 2 6 2 2 2 2 6 2 2 2 2 2 5 1.7 1.3 0.8 TO TO TO 21 0.23 0.0 0.0 3.0 0.1 1.0 78.9 237.0 0.00016 0.06 1.14 2.0 0.014 0.05 0.04 0.0 0.11 0.92 1300.0 0.9 10.0 1.3 0.8 0.0 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE ENDATA4 HYDRAULICS RCH= 1.0 60.0 2.0 2.0 15.0 0.0065 0.035 HYDRAULICS RCH= 2.0 60.0 2.0 2.0 10.0 0.0037 0.040 HYDRAULICS RCH= 3.0 60.0 2.0 2.0 18.0 0.0043 0.035 ENDATA5 TEMP/LCD RCH= 1.0 240.0 0.06 0.3 78.0 74.0 30.1 4.4 TEMP/LCD RCH= 2.0 240.0 0.06 0.3 78.0 74.0 30.1 4.4 TEMP/LCD RCH= 3.0 240.0 0.06 0.3 78.0 74.0 30.1 4.4 ENDATA5A REACT COEF RCH= 1.0 0.23 0.0 0.1 3.0 0.0 0.0 0.0 REACT COEF RCH= 2.0 0.23 0.0 0.1 3.0 0.0 0.0 0.0 REACT COEF RCH= 3.0 0.23 0.0 0.1 3.0 0.0 0.0 0.0 ENDATA6 N AND P COEF RCH= 1.0 0.2 0.0 0.2 0.0 10.0 0.0 0.0 0.0 N AND P COEF RCH= 2.0 0.2 0.0 0.2 0.0 10.0 0.0 0.0 0.0 N AND P COEF RCH= 3.0 0.2 0.0 0.2 0.0 10.0 0.0 0.0 0.0 ENDATA6A ALG/OTHER COEF RCH= 1.0 10.0 0.6 0.04 0.0 0.0 0.0 0.0 ALG/OTHER COEF RCH= 2.0 10.0 0.6 0.04 0.0 0.0 0.0 0.0 ALG/OTHER COEF RCH= 3.0 10.0 0.6 0.04 0.0 0.0 0.0 0.0 ENDATA6B INITIAL COND-1 RCH= 1.0 80.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-1 RCH= 2.0 78.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-1 RCH= 3.0 78.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 ENDATA7 INITIAL COND-2 RCH= 1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-2 RCH= 2.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-2 RCH= 3.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 ENDATA7A INCR INFLOW-1 RCH= 1.0 0.0 70.0 0.0 0.0 0.0 0.0 0.0 0.00.E+00 INCR INFLOW-1 RCH= 2.0 0.0 80.0 8.0 1.0 0.0 0.0 0.0 0.00.E+00 INCR INFLOW-1 RCH= 3.0 0.0 70.0 0.0 0.0 0.0 0.0 0.0 0.00.E+00 ENDATA8 INCR INFLOW-2 RCH= 1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INCR INFLOW-2 RCH= 2.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INCR INFLOW-2 RCH= 3.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 ENDATABA ENDATA9 HEADWTR-1 HDW= 1.0ThomasMP 0.01 80.6 4.0 5.0 0.0 0.0 0.0 ENDATA10 HEADWTR-2 HDW= 1.0 0.00.E+00 17.8 1.5 0.29 0.1 2.98 0.7 0.69 ENDATA10A POINTLD-1 PTL= 1.OHS WRF 0.0 0.0 80.0 7.0 0.0 0.0 0.0 0.0 POINTLD-1 PTL= 2.0Trib1 0.0 0.0 80.0 7.5 1.0 0.0 0.0 0.0 POINTLD-1 PTL= 3.0Trib2 0.0 0.0 80.0 7.5 1.0 0.0 0.0 0.0 ENDATA11 POINTLD-2 PTL= 1.0 0.00.E+00 0.0 0.5 1.0 0.1 3.4 0.27 0.23 POINTLD-2 PTL= 2.0 0.00.E+00 0.0 1.15 0.08 0.05 0.2 0.4 0.06 POINTLD-2 PTL= 3.0 0.00.E+00 0.0 1.15 0.08 0.05 0.2 0.4 0.06 ENDATA11A ENDATA12 DOWNSTREAM BOUNDARY-1 70.0 0.0 0.0 0.0 0.0 0.0 0.00.0E+00 ENDATA13 ENDATA13A BEGIN RCH 1 22 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL PLOT RCH 3 EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE 23 COPYRIGHT 2011 BY CH2M.HILL, INC: ; COMPANY CONFBDENTIAL .✓ 4' EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Attachment A-5 Utley Creek 6mgd Scenario Input File 24 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE TITLE01 TITLE02 TITLE03 NO TITLE04 NO TITLE05 NO TITLE06 YES TITLE07 YES TITLE08 NO TITLE09 YES TITLE10 TITLE11 YES TITLE12 TITLE13 YES TITLE14 NO TITLE15 NO ENDTITLE LIST DATA INPUT WRITE OPTIONAL SUMMARY NO FLOW AUGMENTATION STEADY STATE TRAPEZOIDAL X-SECTIONS NO PRINT LCD/SOLAR DATA PLOT DO AND BOD FIXED DNSTM COND (YES=1)= UTLEY CK 6MGD SCENARIO WHITE OAK SUBBASIN CONSERVATIVE MINERAL I IN CONSERVATIVE MINERAL II IN CONSERVATIVE MINERAL III IN TEMPERATURE BIOCHEMICAL OXYGEN DEMAND ALGAE AS CHL-A IN UG/L PHOSPHORUS CYCLE AS P IN MG/L (ORGANIC-P, DISSOLVED-P) NITROGEN CYCLE AS N IN MG/L (ORGANIC-N, AMMONIA-N, NITRITE-N, NITRATE-N) DISSOLVED OXYGEN IN MG/L FECAL COLIFORMS IN NO./100 ML ARBITRARY NON -CONSERVATIVE 0.0 INPUT METRIC (YES=1) = 0.0 NUMBER OF REACHES = 3.0 NUM OF HEADWATERS = 1.0 TIME STEP (HOURS) 1.0 MAXIMUM ITERATIONS 30.0 LATITUDE OF BASIN (DEG) = 35.6 STANDARD MERIDIAN (DEG) = 75.0 EVAP. COEFF. (AE) • 0.00103 ELEV. OF BASIN (ELEV) 240.0 ENDATA1 O UPTAKE BY NH3 OXID(MG 0/MG N)= 3.43 O PROD BY ALGAE (MG 0/MG A) = 1.6 N CONTENT OF ALGAE (MG N/MG A) = 0.085 ALG MAX SPEC GROWTH RATE(1/DAY)= 2.5 N HALF SATURATION CONST (MG/L) = 0.2 LIN ALG SHADE CO (1/H-UGCHA/L)=0.00075 LIGHT FUNCTION OPTION (LFNOPT) = DAILY AVERAGING OPTION (LAVOPT)= NUMBER OF DAYLIGHT HOURS (DLH) = ALGY GROWTH CALC OPTION(LGROPT)= ALG/TEMP SOLR RAD FACTOR(TFACT)= ENDATA1A ENDATA1B STREAM REACH STREAM REACH STREAM REACH ENDATA2 ENDATA3 FLAG FIELD RCH= 1.0 4 FLAG FIELD RCH= 2.0 5 1.0 2.0 14.0 2.0 0.44 1.ORCH=Below TMP 2.ORCH=Below Trib 1 3.ORCH=Below Trib 2 5D-ULT BOD CONV K COEF = OUTPUT METRIC (YES=1) = NUMBER OF JUNCTIONS = NUMBER OF POINT LOADS = LNTH COMP ELEMENT (DX)= TIME INC. FOR RPT2 (HRS)= LONGITUDE OF BASIN (DEG)= DAY OF YEAR START TIME = EVAP. COEFF. (BE) _ DUST ATTENUATION COEF. _ O UPTAKE BY NO2 OXID(MG 0/MG N)= O UPTAKE BY ALGAE (MG 0/MG A) = P CONTENT OF ALGAE (MG P/MG A) = ALGAE RESPIRATION RATE (1/DAY) = P HALF SATURATION CONST (MG/L)= NLIN SHADE (1/H-(UGCHA/L)**2/3)= LIGHT SATURATION COEF (INT/MIN)= TOTAL DAILY SOLAR RADTN (INT) = TOTAL DAILY SOLAR RADTN (INT) = ALGAL PREF FOR NH3-N (PREFN) = NITRIFICATION INHIBITION COEF = FROM FROM FROM 1 6 2 2 2 6 2 2 2 1.7 1.3 0.8 TO TO TO 25 0.23 0.0 0.0 3.0 0.1 1.0 78.9 237.0 0.00016 0.06 1.14 2.0 0.014 0.05 0.04 0.0 0.11 0.92 1300.0 0.9 10.0 1.3 0.8 0.0 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE FLAG FIELD RCH= 3.0 8 2 6 2 2 2 2 2 5 ENDATA4 HYDRAULICS RCH= 1.0 60.0 2.0 2.0 15.0 0.0065 0.035 HYDRAULICS RCH= 2.0 60.0 2.0 2.0 10.0 0.0037 0.040 HYDRAULICS RCH= 3.0 60.0 2.0 2.0 18.0 0.0043 0.035 ENDATA5 TEMP/LCD RCH= 1.0 240.0 0.06 0.3 78.0 74.0 30.1 4.4 TEMP/LCD RCH= 2.0 240.0 0.06 0.3 78.0 74.0 30.1 4.4 TEMP/LCD RCH= 3.0 240.0 0.06 0.3 78.0 74.0 30.1 4.4 ENDATA5A REACT COEF RCH= 1.0 0.23 0.0 0.1 3.0 0.0 0.0 0.0 REACT COEF RCH= 2.0 0.23 0.0 0.1 3.0 0.0 0.0 0.0 REACT COEF RCH= 3.0 0.23 0.0 0.1 3.0 0.0 0.0 0.0 ENDATA6 N AND P COEF RCH= 1.0 0.2 0.0 0.2 0.0 10.0 0.0 0.0 0.0 N AND P COEF RCH= 2.0 0.2 0.0 0.2 0.0 10.0 0.0 0.0 0.0 N AND P COEF RCH= 3.0 0.2 0.0 0.2 0.0 10.0 0.0 0.0 0.0 ENDATA6A ALG/OTHER COEF RCH= 1.0 10.0 0.6 0.04 0.0 0.0 0.0 0.0 ALG/OTHER COEF RCH= 2.0 10.0 0.6 0.04 0.0 0.0 0.0 0.0 ALG/OTHER COEF RCH= 3.0 10.0 0.6 0.04 0.0 0.0 0.0 0.0 ENDATA6B INITIAL COND-1 RCH= 1.0 80.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-1 RCH= 2.0 78.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-1 RCH= 3.0 78.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 ENDATA7 INITIAL COND-2 RCH= 1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-2 RCH= 2.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-2 RCH= 3.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 ENDATA7A INCR INFLOW-1 RCH= 1.0 0.0 70.0 0.0 0.0 0.0 0.0 0.0 0.00.E+00 INCR INFLOW-1 RCH= 2.0 0.0 80.0 8.0 1.0 0.0 0.0 0.0 0.00.E+00 INCR INFLOW-1 RCH= 3.0 0.0 70.0 0.0 0.0 0.0 0.0 0.0 0.00.E+00 ENDATA8 INCR INFLOW-2 RCH= 1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INCR INFLOW-2 RCH= 2.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INCR INFLOW-2 RCH= 3.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 ENDATA8A ENDATA9 HEADWTR-1 HDW= 1.0ThomasMP 0.01 80.6 4.0 5.0 0.0 0.0 0.0 ENDATA10 HEADWTR-2 HDW= 1.0 0.00.E+00 17.8 1.5 0.29 0.1 2.98 0.7 0.69 ENDATA10A POINTLD-1 PTL= 1.0HS WRF 0.0 9.28 80.0 7.0 0.0 0.0 0.0 0.0 POINTLD-1 PTL= 2.0Trib1 0.0 0.0 80.0 7.5 1.0 0.0 0.0 0.0 POINTLD-1 PTL= 3.0Trib2 0.0 0.0 80.0 7.5 1.0 0.0 0.0 0.0 ENDATAII POINTLD-2 PTL= 1.0 0.00.E+00 0.0 0.5 1.0 0.1 3.4 0.27 0.23 POINTLD-2 PTL= 2.0 0.00.E+00 0.0 1.15 0.08 0.05 0.2 0.4 0.06 POINTLD-2 PTL= 3.0 0.00.E+00 0.0 1.15 0.08 0.05 0.2 0.4 0.06 ENDATAIIA ENDATA12 DOWNSTREAM BOUNDARY-1 70.0 0.0 0.0 0.0 0.0 0.0 0.00.0E+00 ENDATA13 ENDATA13A 26 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE BEGIN RCH 1 PLOT RCH 1 2 3 27 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL r r r EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE Attachment A-6 Utley Creek 8mgd Scenario input File 28 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE TITLE01 TITLE02 TITLE03 NO TITLE04 NO TITLE05 NO TITLE06 YES TITLE07 YES TITLE08 NO TITLE09 YES TITLE10 TITLE11 YES TITLE12 TITLE13 YES TITLE14 NO TITLE15 NO ENDTITLE LIST DATA INPUT WRITE OPTIONAL SUMMARY NO FLOW AUGMENTATION STEADY STATE TRAPEZOIDAL X-SECTIONS NO PRINT LCD/SOLAR DATA PLOT DO AND BOD FIXED DNSTM COND (YES=1)= 0.0 INPUT METRIC (YES=1) = 0.0 NUMBER OF REACHES = 3.0 NUM OF HEADWATERS = 1.0 TIME STEP (HOURS) = 1.0 MAXIMUM ITERATIONS = 30.0 LATITUDE OF BASIN (DEG) = 35.6 STANDARD MERIDIAN (DEG) = 75.0 EVAP. COEFF. (AE) = 0.00103 ELEV. OF BASIN (ELEV) = 240.0 ENDATA1 O UPTAKE BY NH3 OXID(MG 0/MG N)= 3.43 O PROD BY ALGAE (MG 0/MG A) = 1.6 N CONTENT OF ALGAE (MG N/MG A) = 0.085 ALG MAX SPEC GROWTH RATE(1/DAY)= 2.5 N HALF SATURATION CONST (MG/L) = 0.2 LIN ALG SHADE CO (1/H-UGCHA/L)=0.00075 LIGHT FUNCTION OPTION (LFNOPT) = 1.0 DAILY AVERAGING OPTION (LAVOPT)= 2.0 NUMBER OF DAYLIGHT HOURS (DLH) = 14.0 ALGY GROWTH CALC OPTION(LGROPT)= 2.0 ALG/TEMP SOLR RAD FACTOR(TFACT)= 0.44 ENDATA1A ENDATA1B STREAM REACH 1.ORCH=Below TMP STREAM REACH 2.ORCH=Below Trib 1 STREAM REACH 3.ORCH=Below Trib 2 ENDATA2 ENDATA3 FLAG FIELD RCH= 1.0 4 FLAG FIELD RCH= 2.0 5 FLAG FIELD RCH= 3.0 8 UTLEY CK 8MGD SCENARIO WHITE OAK SUBBASIN CONSERVATIVE MINERAL I IN CONSERVATIVE MINERAL II IN CONSERVATIVE MINERAL III IN TEMPERATURE BIOCHEMICAL OXYGEN DEMAND ALGAE AS CHL-A IN UG/L PHOSPHORUS CYCLE AS P IN MG/L (ORGANIC-P, DISSOLVED-P) NITROGEN CYCLE AS N IN MG/L (ORGANIC-N, AMMONIA-N, NITRITE-N, NITRATE-N) DISSOLVED OXYGEN IN MG/L FECAL COLIFORMS IN NO./100 ML ARBITRARY NON -CONSERVATIVE 5D-ULT BOD CONV K COEF = OUTPUT METRIC (YES=1) = NUMBER OF JUNCTIONS = NUMBER OF POINT LOADS = LNTH COMP ELEMENT (DX)= TIME INC. FOR RPT2 (HRS)= LONGITUDE OF BASIN (DEG)= DAY OF YEAR START TIME = EVAP. COEFF. (BE) _ DUST ATTENUATION COEF. _ O UPTAKE BY NO2 OXID(MG 0/MG N)= O UPTAKE BY ALGAE (MG 0/MG A) = P CONTENT OF ALGAE (MG P/MG A) = ALGAE RESPIRATION RATE (1/DAY) = P HALF SATURATION CONST (MG/L)= NLIN SHADE (1/H-(UGCHA/L)**2/3)= LIGHT SATURATION COEF (INT/MIN)= TOTAL DAILY SOLAR RADTN (INT) = TOTAL DAILY SOLAR RADTN (INT) = ALGAL PREF FOR NH3-N (PREFN) = NITRIFICATION INHIBITION COEF = FROM FROM FROM 1 6 2 2 2 6 2 2 2 2 6 2 2 2 2 2 5 1.7 1.3 0.8 TO TO TO 29 0.23 0.0 0.0 3.0 0.1 1.0 78.9 237.0 0.00016 0.06 1.14 2.0 0.014 0.05 0.04 0.0 0.11 0.92 1300.0 0.9 10.0 1.3 0.8 0.0 COPYRIGHT 2011 BY CH2M HILL, INC. • COMPANY CONFIDENTIAL r r EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE ENDATA4 HYDRAULICS RCH= 1.0 60.0 2.0 2.0 15.0 0.0065 0.035 HYDRAULICS RCH= 2.0 60.0 2.0 2.0 10.0 0.0037 0.040 HYDRAULICS RCH= 3.0 60.0 2.0 2.0 18.0 0.0043 0.035 ENDATA5 TEMP/LCD RCH= 1.0 240.0 0.06 0.3 78.0 74.0 30.1 4.4 TEMP/LCD RCH= 2.0 240.0 0.06 0.3 78.0 74.0 30.1 4.4 TEMP/LCD RCH= 3.0 240.0 0.06 0.3 78.0 74.0 30.1 4.4 ENDATA5A REACT COEF RCH= 1.0 0.23 0.0 0.1 3.0 0.0 0.0 0.0 REACT COEF RCH= 2.0 0.23 0.0 0.1 3.0 0.0 0.0 0.0 REACT COEF RCH= 3.0 0.23 0.0 0.1 3.0 0.0 0.0 0.0 ENDATA6 N AND P COEF RCH= 1.0 0.2 0.0 0.2 0.0 10.0 0.0 0.0 0.0 N AND P COEF RCH= 2.0 0.2 0.0 0.2 0.0 10.0 0.0 0.0 0.0 N AND P COEF RCH= 3.0 0.2 0.0 0.2 0.0 10.0 0.0 0.0 0.0 ENDATA6A ALG/OTHER COEF RCH= 1.0 10.0 0.6 0.04 0.0 0.0 0.0 0.0 ALG/OTHER COEF RCH= 2.0 10.0 0.6 0.04 0.0 0.0 0.0 0.0 ALG/OTHER COEF RCH= 3.0 10.0 0.6 0.04 0.0 0.0 0.0 0.0 ENDATA6B INITIAL COND-1 RCH= 1.0 80.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-1 RCH= 2.0 78.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-1 RCH= 3.0 78.6 0.0 0.0 0.0 0.0 0.0 0.0 0.0 ENDATA7 INITIAL COND-2 RCH= 1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-2 RCH= 2.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INITIAL COND-2 RCH= 3.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 ENDATA7A INCR INFLOW-1 RCH= 1.0 0.0 70.0 0.0 0.0 0.0 0.0 0.0 0.00.E+00 INCR INFLOW-1 RCH= 2.0 0.0 80.0 8.0 1.0 0.0 0.0 0.0 0.00.E+00 INCR INFLOW-1 RCH= 3.0 0.0 70.0 0.0 0.0 0.0 0.0 0.0 0.00.E+00 ENDATA8 INCR INFLOW-2 RCH= 1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INCR INFLOW-2 RCH= 2.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 INCR INFLOW-2 RCH= 3.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 ENDATA8A ENDATA9 HEADWTR-1 HDW= 1.0ThomasMP 0.01 80.6 4.0 5.0 0.0 0.0 0.0 ENDATA10 HEADWTR-2 HDW= 1.0 0.00.E+00 17.8 1.5 0.29 0.1 2.98 0.7 0.69 ENDATA10A POINTLD-1 PTL= 1.0HS WRF 0.0 12.38 80.0 7.0 0.0 0.0 0.0 0.0 POINTLD-1 PTL= 2.0Trib1 0.0 0.0 80.0 7.5 1.0 0.0 0.0 0.0 POINTLD-1 PTL= 3.0Trib2 0.0 0.0 80.0 7.5 1.0 0.0 0.0 0.0 ENDATA11 POINTLD-2 PTL= 1.0 0.00.E+00 0.0 0.5 1.0 0.1 3.4 0.27 0.23 POINTLD-2 PTL= 2.0 0.00.E+00 0.0 1.15 0.08 0.05 0.2 0.4 0.06 POINTLD-2 PTL= 3.0 0.00.E+00 0.0 1.15 0.08 0.05 0.2 0.4 0.06 ENDATA11A ENDATA12 DOWNSTREAM BOUNDARY-1 70.0 0.0 0.0 0.0 0.0 0.0 0.00.0E+00 ENDATA13 ENDATA13A BEGIN RCH 1 30 COPYRIGHT 2011 BY CH2M HILL. INC. • COMPANY CONFIDENTIAL 4 PLOT RCH 1 2 3 EVALUATION OF PROPOSED UTLEY CREEK DISCHARGE 31 COPYRIGHT 2011 BY CH2M RILL, INC. • COMPANY CONFIDENTIAL • Prrogress firvairgy Stephanie L. Sudano, P.E. Director of Engineering Town of Holly Springs P 0 Box 8 128 South Main Street Holly Springs, NC 27540 Eu,4441 Subject: Progress Energy Shearon Harris Expansion Project Plans for Utley Creek and GreenTree Reservoir Dear Ms. Sudano: Carolina Power & Light Company d/b/a Progress Energy Carolinas, Inc. (Progress) is pursuing permits and approvals to construct and operate two new nuclear power generation units at the existing Shearon Harris Nuclear Plant near New Hill, NC. The project also includes expansion of Harris Lake by raising its spillway elevation from 220' above mean sea level (amsl) to 240' amsl. As part of the 'permitting process, Progress expects to be required by federal and state permitting agencies to provide compensatory mitigation for impacts to wetlands and streams resulting from the lake rise. Progress has identified the Utley Creek system as a candidate for restoration and/or enhancement activities that would be part of the overall compensatory mitigation plan for the Harris expansion project. The area currently known as the Green Tree Reservoir will be inundated when the lake rises to the 240' elevation. When inundated, the Green Tree Reservoir area is expected to support aquatic vegetation typical of fringe and emergent wetlands currently found around Harris Lake, as well as create conditions conducive to the development of bottomland hardwood wetlands in adjacent areas. Over the next several years, Progress intends to use the Green Tree Reservoir area to conduct a pilot project to study the development of fringe, emergent and forested wetlands at the 240' elevation. The study will involve ad'usting water levels behind the water control structure at the Green Tree and monitoring vegetative planting pots to eva uate various p ant species and wetland formation rates. These studies will help Progress and the federal and state permitting agencies evaluate the potential for wetlands to successfully form at the new lake level. When Harris Lake is raised to its future elevation, this area will become part of the lake. If you have questions or would like additional information please feel free to contact Linda Hickok at 919-546-7095. Alan Madewell , Manager - Environmental Energy Supply - Carolinas Progress Energy Carolinas, Inc. Pt) Hex 1551 Raleigh, %C 21607 • Belnick, Tom • From: BiII.Kreutzberger@CH2M.com Sent: Friday, June 03, 2011 12:18 PM To: Belnick, Tom; Stecker, Kathy Cc: stephanie.sudano@hollyspringsnc.us; Klaus.Albertin@CH2M.com; Ruth.Swanek@CH2M.com; mslusher@dmp-inc.com; Wakild, Chuck; Clark, Alan; Poupart, Jeff; Matthews, Matt; Reid, Dianne; Blaisdell, Daniel; Manning, Jeff; Colson, Kim; Behm, Pamela Subject: Holly Springs NPDES Permit - Modeling and letter from Progress Energy Attachments: Utley Ck QUAL2E TM-6-3-2011.pdf; Progress Energy Letter 06022011.pdf Tom and Kathy — Attached is technical memorandum describing the water quality modeling analysis and a letter from Progress Energy describing their plan for a mitigation project in the Greentree Reservoir area of Utley Creek that would include a wetland area — similar to what will be there when the lake level is raised. Please contact me or Stephanie Sudano if you have any questions or require additional information. Thanks Bill Bill Kreutzberger 1 CH2M HILL] Charlotte Office) Direct Phone (704) 543-3269 (Mobile (704)904-5918 'Email - biI I. kreutzberger@ch 2m. com From: Wakild, Chuck[mailto:chuck.wakild@ncdenr.govl Sent: Thursday, May 26, 2011 11:39 AM To: Matthews, Matt; Poupart, Jeff; Belnick, Tom; Clark, Alan; Reid, Dianne; Stecker, Kathy; Manning, Jeff; Blaisdell, Daniel; Colson, Kim; Kreutzberger, Bill/CLT Subject: FW: Holly Springs NPDES Permit FYI. We are relying on the current USGS flow metrics and expect to hear from Holly Springs within a few weeks for the modeling and Progress Energy agreement. From: Wakild, Chuck Sent: Thursday, May 26, 2011 11:29 AM To: 'stephanie.sudano@hollyspringsnc.us' Cc: Sullins, Coleen; Matthews, Matt; Clark, Alan; 'vpowell@nccommerce.com' Subject: Holly Springs NPDES Permit Stephanie, We have reviewed the request from the Town of Holly Springs to relocate their discharge point to Utley Creek just downstream of Thomas Mill Pond. The DWQ can reissue the Holly Springs NPDES Permit provided all of the necessary support documentation demonstrates compliance with water.quality standards downstream of the relocated discharge point. The following processing steps and demonstrations are necessary: • _Holly Sprines will be provided speculative effluent limits for the new location if they submit a water quality modeling analysis which demonstrates compliance with standards and they submit documentation that the downstream reservoir (Greentree Reservoir) will remain unimpounded into the future. We understand that Progress Energy owns and operates that asseThive must agree to this condition. If and when speculative e ` uent limits are provided, Holly Springs must revise and resubmit an Environmental Assessment (EA) document for processing through the State Environmental Policy Act (SEPA). This process 1 requires a public comment period. The best case outcome for Holly Springs is a Finding of No Significant Impact (FONSI). o If and when a FONSI is issued, Holly Springs may submit an NPDES Permit application reflecting the new location and increased effluent flow. Processing of this permit application also requires a public comment period. o If and when the revised NPDES Permit issues, Holly Springs must submit engineering plans and specifications for the construction of a new effluent transport and discharge structure at the new location. After review, DWQ will issue an Authorization to Construct (ATC). Depending on the particular design, there may be a need for approvals to impact wetlands as well. Issuance of these approvals is never absolutely certain given the opportunities for public input. Also, the length of time it will take to complete these steps is dependent on not only DWQ review time, but how long various submittals take to prepare and the quality (completeness and thoroughness) of those submittals, and what information may be brought forward from the public. I believe the absolute minimum time needed to complete this entire process from where we are today to issuance of the ATC is 12 months. If you have questions, call me at 919-807-6358. Please note my new email address: chuck.wakild(i?ncdenr.gov E-mail is a public record and e-mail messages are subject to public review and may be disclosed to third parties. E- mail is subject to the Public Records Law and applicable records retention schedule. 2 r THE TOWN OF Iiolly Springs P.O. Box 8 128 S. Main Street Holly Springs, N.C. 27540 www.hollyspringsne.us (919) 552-6221 Fax: (919) 552-5569 Mayor's Office Fax: (919) 552-0654 October 28, 2010 Mr. Matt Matthews NC Division of Water Quality Surface Water Protection Section 1617 Mail Service Center Raleigh, NC 27699-1617 Re: Town of Holly Springs Utley Creek WRF Project 10-007 Discharge Alternatives Evaluation Dear Mr. Matthews: This letter is in follow up to several conversations over the past couple of weeks between our consultant, myself, and both you and Hannah Stallings and also to your letter of October 22, 2010. We acknowledge receipt of your decision regarding removal of our discharge from its current location, primarily because of water quality concerns related to Thomas Mill Pond (TMP). However, our current EA and EAA documents evaluate three possible discharge locations in the Harris Lake watershed. These include a discharge at our present location above TMP, a potential discharge point below TMP, and a potential discharge directly to Harris Lake (where we currently have speculative limits). We believe that the former Green Tree Reservoir no longer functions as a reservoir and is primarily a stream (as indicated in the photo and 2010 Google Earth image attached to this letter). Therefore, we believe the specific water quality issues that you used as a basis for the decision to move our discharge, do not apply to a discharge below TMP. Holly Springs hereby requests speculative permit limits at the location on Utley Creek immediately below TMP as indicated in our EA and EAA. We plan to incorporate this information — once we receive it. - into our EA document for our discharge. We will then submit a revised document to Ms. Stallings. In order to expedite the development and issuance of speculative limits, we would like to offer assistance in the form of a consultant to work with DWQ to develop the speculative limits. We are requesting a meeting at your earliest convenience to discuss what DWQ would like to see in such a scope of work. October 25, 2010 Mr. Matt Matthews NC Division of Water Quality Page 2 As you may know, we need to move forward as expeditiously as possible on this project. As promised in an earlier conversation, attached is the additional data from the Utley Creek monitoring that we have been conducting. Thank you for consideration of this request. Please contact me at 919-291- 9796 or 919-5 57-3 93 5 should you need any additional information from us. Sincerely, Stephanie L. Sudano, PE Director of Engineering cc: Hannah Stallings, DWQ Mike Slusher, PE, DMP Phil May, Carolina Ecosystems Carl Dean, Town Manager, TOHS John Schifano, Town Attorney, TOHS Amy Moore, Director Public Utilities, TOHS Project file paper/electronic/correspondence 13386 /sls PPOES -arm d- 61eIVC004399L ATAi NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary Stephanie L. Sudano, PE Director of Engineering Town of Holly Springs P.O. Box 8 128 S. Main Street Holly Springs, NC 27540 October 22, 2010 Subject: Town of Holly Springs Utley Creek WRF Project 10-007 Discharge Alternatives Evaluation Ms. Sudano, In response to your letters of May 7 and October 8, 2010 and based on my review of data submitted by the Town, data collected by Division of Water Quality field staff, and conversations with Linda Hickok of Progress Energy, I reaffirm the Division's longstanding previous decision directing Holly Springs to remove its wastewater discharge from Utley Creek. Thank you for providing the follow-up information regarding plant startup and phosphorus monitoring data demonstrating that phosphorus removal at the wastewater facility has significantly improved since the fall 2009 noncompliance. As you pointed out, the NC water quality standard of 40 ug/L for chlorophyll a does not apply to Thomas Mill Pond due to its size. However, I believe that the elevated chlorophyll levels recorded in the pond indicate a potential for severe algal blooms. Such blooms, as well as fish kills, have occurred historically in the pond and prompted the Division's initial decision to remove the discharge from the creek. The size of the pond has not changed significantly despite the failure of the pond's dam structure. In addition, conversations with Linda Hickok of Progress Energy indicate that restoration of the dam structure is still a possibility, though there are currently no definite plans for this. During our siaff's site visit in September, conductivity was measured at the wastewater effluent, upstream, and downstream of the wastewater outfall. The values collected are as follows: Upstream 65 umhos/cm Effluent 348 Thomas Mill Pond near dam 344 Greentree Reservoir near dam 331 Surface Water Protection Section 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury Si Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919-807-64941 Customer Service:1-877.623-6748 Internet www.ncwaterquality.org An Equal Opportunity! Affirmative Action Employer None Cazolina �turally Stephanie Sudano 10/22/2010 Page 2 of 2 As suggested by the level of conductivity measured in the receiving stream, I remain concerned about the potential adverse effects on the aquatic life of Utley Creek. Also, keep in mind that these values were collected within a few days of a major rain event. In your letter and in the EA document, there is an "adaptive approach" described that implies an evaluation of the discharge's effect on the creek either at the current discharge location or at a location downstream of Thomas Mill Pond. Typically, such studies would logically occur prior to a new or expanding wastewater discharge occurring in a receiving stream, as opposed to after, as is described here. As stated in previous communications, continued discharge to Utley Creek is not an option. If you have further questions regarding this issue, please call me at (919) 807-6384 or email me at matt.matthews@ncdenr. gov. Sincerely, a Matt Matthews Surface Water Protection Section Chief cc: Coleen H. Sullins Jeff Poupart Danny Smith Tom Belnick Jay Sauber Hannah Stallings