NC0026441_Staff Comments_20110803

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NC Division of Water Quality
Planning Section CF
Modeling and TMDL Unit
MEMORANDUM
To: Tom eelnick, Complex Permitting Unit Supervisor
From:
Andy Painter, Environmental Specialist
Through:
Kathy Stecker, Modeling Unit Supervisor
CC:
Alan Clark, Nora Deamer, Julie Grzyb
Date: April 5, 2011
Subject: Siler City WWTP 2011 Permit Renewal
Introduction
The Siler City WWTP discharges into Loves Creek in the Rocky River Watershed of
the Cape Fear River Basin. The WWTP is currently operating without total nitrogen (TN)
limits. The average TN effluent concentration from 2004 to 2008 was 31.5 mg/L. High
nitrogen levels discharged from this WWTP are resulting in high nitrogen concentrations
at the downstream sampling locations on Loves Creek and further downstream in the
Rocky River. These high levels of nitrogen are likely contributing to excess aquatic plant
and algal growth observed in the Rocky River downstream of the WWTP and
chlorophyll -a violations at Woody's Dam. Incorporation of total nitrogen limits at the
best available technology level for the Siler City WWTP 2011 NPDES permit renewal is
recommended to improve water quality in Loves Creek and the Rocky River.
Ambient Monitoring Data:
The Upper Cape Fear River Basin Association monitors water quality upstream and
downstream of the WWTP on Loves Creek, and also on the Rocky River, upstream and
downstream of the mouth of Loves Creek. Both downstream sites show significant
increases in total nitrogen compared with respective upstream sites. Data from May
2009 through December 2010 shows a median total nitrogen concentration of 18.1
mg/L for monitoring site B5920000, downstream of the WWTP on Loves Creek,
compared to 1 mg/L for the upstream monitoring site B5890000. The median total
nitrogen concentration for monitoring site B5980000, downstream of Loves Creek on
the Rocky River was 7.8 mg/L while the upstream site B5950000 measured 0.9 mg/L.
The DWQ Ambient Monitoring Site B6000000 is located on the Rocky River
approximately 10 miles downstream of the mouth of Loves Creek. The median total

nitrogen concentration was 3.8 mg/L for this site during the same time period. The
locations and median total nitrogen concentrations for the monitoring sites are shown
in Figure 1; monitoring data is also summarized in Table 1.
NC State Rocky River Monitoring Project
In 2009 the NC State Cooperative Extension Service conducted a short term monitoring
project for the Rocky River to document chlorophyll -a and nutrient levels. Three sites
along the river were sampled at Carolina Hill Road, Woody's Dam Lake, and at Chatham
Church Road. The mean chlorophyll -a concentrations along the two riverine sites were
2.5 and 11.3 ug/L, however then median chlorophyll -a concentration at Woody's Dam
(-18 miles downstream of Loves Creek) was 49.3 ug/L, well exceeding the 40 ug/L water
quality standard. In addition, 7 out of the 10 samples collected exceeded the standard.
Woody's Dam is therefore assessed as impaired for aquatic life, and will be included on
North Carolina's 2012 303(d) list.
Both phosphorus and nitrogen are essential for phytoplankton growth, and both have
been found to be simultaneously or alternately limiting in NC impoundments. While we
have no site -specific algal assay results for Woody's Dam, we recommend that both
nitrogen and phosphorus be considered as contributing to the chlorophyll -a
impairment.
2

-PB5950000 Rocky River - Upstream
a April 2009 December 2010
t Median Total Nitrogen a .89 mg1L
e �
- 65920000 Loves Creek - Downstream
April 2009 - December 2010
Median Total Nitrogen - 18.07 mg& -
•135890000 Loves Creek - Upstream
April 2009 - December 2010 \
Median Total Nitrogen = .97 mg1L
B5980000 Rocky River -Downstream
April 2009 -December 2010
Median Total Nitrogen a 7.77 moll-
-
t
4�
O.
r
-
B6000000 Rocky River - -10 Miles Downstream
April 2009 - December 2010
Median Total Nitrogen = 3.79 mg1L s
i
Woody's Dam
Legend
Leek .tune - September 2009
-- Median Chlorophyll -a = 49.3 ug1L�. .
Q Sher City WWTP
_
Q Monitoring Site
0
1 2 4 Miles
G e.at�° ;.
2010Imp aired Water
r °O4osCro�
,m
Figure 1. Water quality monitoring sites
3

Table 1. Total nitrogen monitoring in the Rocky River Watershed- May 2009-December
2010
UCFRBA Monitoring Sites
DWQ AMS Site
Date
B5890000
B5920000 B5950000
B5980000
Date
B6000000
5/12/2009
5.82
1.32
1.26
3.37
5/6/2009
4.97
6/2/2009
1.03
28.80
0.89
5.02I
6/3/2009
4.83
7/13/2009
2.28
2.53
0.39
14.70I
7/28/2009
7.21
8/4/2009
0.61
34.80
0.41
13.80I
9/8/2009
8.15
9/17/2009
0.60
36.60
0.90
25.20I
12/1/2009
2.29
10/20/2009
0.34
33.40
0.61
19.00
3/8/2010
1.13
11/30/2009
1.05
13.00
1.36
2.76
6/1/2010
2.43
12/28/2009
0.91
13.72
1.24
1.50
9/8/2010
2.53
1/18/2010
1.35
2.80
1.41
1.55
12/14/2010
3.79
2/15/2010
0.84
6.64
1.33
1.92
3/23/2010
0.38
9.35
0.89
1.73
4/26/2010
4.38
19.84
0.67
6.28I
5/18/2010
1.22
11.23
0.84
8.10I
6/30/2010
2.87
19.80
0.63
9.18
7/27/2010
0.63
29.70
0.63
9.87
8/17/2010
0.70
25.00
1.14
9.28
9/14/2010
0.40
28.60
0.86
7.43
10/26/2010
2.16
9.63
0.75
10.09
11/23/2010
0.33
22.00
1.01
8.26
12/20/2010
1.29
16.33
1.24
4.89
Median
0.97
18.07
0.89
7.77
Median
3.79
Average
1.46
18.25
0.92
8.20
Average
4.15

B6960000 RockyRiver- Upstream
April 2009, December 2010
Median -total Mtrogen -.89 mglL
Nam/
B6920000 Loves Creek - Dovmatroam
—,`April
2009 - December 2010
Median Total Nitrogen -18.07 mglL
Upstream
2010
-.97mgIL
B6980April000 Rocky River vnatream
r2010
April -December 2010
Median Total Mtrogen - 777 mglL
B6000000 Rocky River --10 Miles
April 2009 - December 2010
Median Total Mtrogen = 3.79 mglL
-� Woody'e Dam
er 2009
Legend -`-I �/ve✓e°"` MedianJune - aptembhyl"=
�L.� Median CNorophylla =49.3 ug/L
SIerCkyWWTP
® Monuonng6de 1.a 0 1 2 4Miles f o ppce,.
— 20701mpeked Wafer
Figure 1. Water quality monitoring sites
NlY�
3

Grzyb, Julie
From:
Belnick, Tom
Sent:
Tuesday, April 05, 2011 10:57 AM
To:
Grzyb, Julie
Subject:
FW: draft memo on Rocky River
Attachments:
Siler City WWTP Memo (2).docx
Siler City Renewal- Part 1 of 2
Julie- Coleen has stated that Siler City will get a TN limit at permit renewal, based on additional data collected showing
their large contribution of TN to the receiving waterbody. You have this renewal.
Tom Belnick
Supervisor, Complex NPDES Permitting Unit
NC DENR/Division of Water Quality
1617 Mail Service Center, Raleigh, NC 27699-1617
[phone]; fax [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.
From: Stecker, Kathy
Sent: Monday, April 04, 20112:18 PM
To: Belnick, Tom
Cc: Deamer, Nora; Painter, Andy; Manning, Jeff
Subject: draft memo on Rocky River
Tom
Attached is a brief DRAFT memo with recommendations and supporting data for the Siler City renewal. Please take a
look and let us know if this is adequate, and if not, what else you would like to see included. Note that we did not
provide information from RRO's study of the Rocky River watershed; I'm sure you can incorporate that into your
documentation as well, if needed.
-Kathy
Kathy Stecker
NCDWQ
919-807-6422
[e-mail]
NOTICE: Emails sent to and from this account are subject to Public Records Law and may be
disclosed to third parties.

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Information Item: 11-01 Rockv River Water Quality Update — /V /C1 6e1-4Y1 O, &I N
Explanation: Staff will present an update of water quality conditions in Rocky River, V
a tributary to the Deep River in -the Cape Fear River Basin. The
presentation will include a discussion of some new and ongoing
•� 1 ��� management issues. These include, but are not limited to, future
changes to the 303(d) list, follow up on flow conditions in the 401 Water
Quality Certification for Siler City's lower reservoir, and nutrient source
C� identification in the watershed.
A
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Tom
Subject:
FW: Slier City W WTP issue
Location:
9 th floor file room
Start:
Tue 1/4/2011 1:30 PM
End:
Tue 1/4/2011 2:45 PM
Recurrence:
(none)
Meeting Status:
Accepted
O1iC WZ-7 V�dil4
Organizer: Deamer, Nora , !� /)_ / %0 K� �^L r1
When: Tuesday, January 04, 2011 1:30 PM-2:45 PM (GMTT-005:00)(Eastern \Time (US & Canada).v"� YYY ��,
Where: 9 th floor file room / L M%V
Note: The GMT offset above does not reflect daylight saving time adjustments.
�✓ i®h� fi rotJ/� 0,1 ro c,Ks
-----Original Appointment -----
From: Deamer, Nora
Sent: Wednesday, December 15, 2010 9:28 AM
To: Deamer, Nora; Stecker, Kathy; Poupart, Jeff; Smith, Danny; Manning, Jeff; Clark, Alan /J/Lry
Subject: Siler City WWTP issue
When: Tuesday, January 04, 2011 1:30 PM-2:45 PM (GMT-05:00) Eastern Time (US & Canada).
Where: 9 th floor file room
When: Tuesday, January 04, 20111:30 PM-2:45 PM (GMT-05:00) Eastern Time (US & Canada).
Where: 9 th floor file room
Note: The GMT offset above does not reflect daylight saving time adjustments.
The meeting date has changed. Jeff P - Danny sent an email indicating that you have reserved the 9th FCR for this meeting.
Thanks!
Nora
I would like to review Rocky River issues and what are the possibilities of modifying Siler City's W WTP limits for their upcoming 2011
permit.
I will be presenting Rocky River information to the January EMC. The NPDES permit will come up and I would like for us all to be
ready.
If this dates doesn't work how about Jan 4"' at 1pm? I would like to touch base before the pre -meeting on the 6`h of January.
Thanks
Nora

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Summary of Activities in the Rocky River Watershed (0303000305) — Cape Fear River Basin
During the EMC NPDES Subcommittee Meeting in January 2010, concern was raised regarding protection of
the Rocky River in Chatham County. The following provides a brief history and overview of ongoing activities
within this watershed as of December 2010.
A. 401 Water Quality Certification for Expansion of Slier City's Lower Drinking Water Reservoir (Turner
Reservoir) — Requirement to Develop the Rocky River Management Team
As part of the 401 water quality certification for the expansion of Siler City's lower drinking water reservoir, Siler City
agreed to participate on a management team consisting of participants from DWQ, Division of Water Resources, NC
Wildlife Resources Commission, US Fish and Wildlife Service, Friends of the Rocky River, Rocky River Heritage
Foundation and Siler City. The reservoir management team was established to guide the Division in its efforts to ensure
the optimum operation of the reservoir for the protection and improvement of the quality of the Rocky River. This team
is also required to review the need for additional monitoring or studies of the river that will enable a better
understanding of the cause of the excessive growth of aquatic plants that have been observed downstream of the
reservoir.
Due to concerns of the local citizens about the amount of aquatic macrophytic algal/periphyton rg ow.th downstream of
the reservoir, the"401 certification requires a 20 cfs pulse released from the dam every 30 days. This requirement was
intended to mimic a natural storm event and dislodge filamentous algal mats that occur along the river. The dam was
approved by the Division of land Resources Dam Safety Program on October 22, 2009 and the Turner Reservoir was full
on November 13, 2009.
B. Slier City WWTP Permit (NC0026441)
On April 25, 2006, Siler City submitted an application for renewal of its existing wastewater permit. The Division of
Water Quality held a public hearing on the draft wastewater permit on April 17, 2008. Based on recommendations of
the hearing officers, DWQ added to the permit:
1) Winter total phosphorus (TP) limits of 2 mg/L;
2) Increased frequency of effluent total nitrogen (TN) monitoring from monthly to weekly;
3) Reporting of TN.. NO2+NO3 and TKN effluent concentrations in addition to parameters already reported;
4) Additional instream monitoring on Loves Creek upstream and downstream of the discharge; and
5) Development of a Nutrient Removal Optimization Plan within one year from the effective date of the final
permit.
The Division Director approved the Siler City NPDES wastewater permit on August 29, 2008. The Friends of Rocky River
challenged the renewal of the permit on whether it meets water quality standards for "best uses"; protects and
preserves downstream "existing uses"; and addresses all cumulative and secondary impacts of all other pollution
sources within the watershed. The Administrative Law Judge entered a decision recommending that the EMC affirm the
reissuance of the permit. The NPDES committee of the EMC affirmed the renewal of the permit on January 1% 2010.
However, the committee members expressed support for the Friends of Rocky River's efforts to protect and restore the
river water quality. Slier City's NPDES permit will expire October 31, 2011.
Rocky River (CPF) WQC Update 1 12/2010

C. NC 2010 303(d)/Integrated Report Listings and Water Quality Data for the Rocky River Watershed (2004-2008)
Table 1. 2010 303(d) listed waters. Data window for 2010 is 1/1/2004-12/31/2008.
Name
Length/Area
Description
Assessment
Rocky River
214 acres
Upper Rocky River Reservoir
Impaired - Chlorophyll a (80%> 40µ JL Chi a)
Rocky River
6.7 mi
From dam at lower/Turner
Impaired - Low Dissolved Oxygen
Reservoir to Varnal Cr.
(13%<4 mg/L DO at B5950000)
Not Rated — Benthos (BB192)
Rocky River
21.6 mi
From Varnal Cr. to Deep River
Not Rated — High Nitrogen Levels
(not listed as
(> 10 mg/L NO2+NO3; 32% at B5980000 &
impaired)
11%at B60000000)
Not Rated — Benthos(BB376)
Loves Creek
6.2 mi
Source to Rocky River
Impaired — Benthos (2003 assessment)
Tick Creek
8.2 mi
Source to US 421
Impaired — Fish (BF72)
Bear Creek
2.0 mi
From SR 2189 to SR 2187
Impaired — Benthos (BB495)
40
35
30
J
m
E 25
c
w
2 20
2
1
N 5
0
~ 10
5
01104 07104 01105 07I05 01106 07108 01107 07107 01108 07108 01109
- B5950000 • At US 64 (Upstream of Loves Cr.)
t BS980000 - Near Siler City (Downstream of Loves Cr.)
— B6000000- Near Pittsboro(Downstream of Loves Cr.)
Figures
la. Rocky River ambient monitoring stations instream
total nitrogen concentrations for 2010 IR period.
1b. Siler City's WWTP effluent total nitrogen
concentration for 2010 IR period (mean TN
concentration is 31.5 mg/L).
1c. Loves Creek and Rocky River instream total
nitrogen contractions for April 2009-September 2010.
(Loves Creek stations initiated in April 2009 in response
to permit renewal requirements.)
70
Fig. lb
60
: 50
E
E
c 40
m
O
Z 30
F 20
10
0
01104 07104 01105 07105 01106 07106 01107 07/07 01/08 07108 01109
40
J 30
0
— B6890000 - Loves Cr. Upstr c W WTP
Fig.1c �85920000- Loves Cr. DwnstrOfWWTP
—�— B6960000 - Rocky R. Upstr of Loves Cr.
-+ B6980000 - Rocky R. Dwnstr of Loves Cr
05109 07109 09109 11109 01/10 03/10 05I10 07110 09110
Rocky River (CPF) WQC Update 2 12/2010

Loves Creek— B5920000
(Downstream of WWTP)
Mean TN = 20.49 mg/L ISiler
City
Loves Creek —B5800� r
(Upstream of WWTP)
Mean TN =1.49
N
A
Rocky River 0303000305 ORANGE
f1LAMANCE
\c
490
000
1
Mcado w
Creek
n�
n
reek
G 1 a
0 1 2
Rocky River — B5950000
(Upstream of Loves Creek)
Mean TN = 0.37 mg/L
Rocky River — B5980000
(Downstream of Loves Cr.)
Mean TN = 9.78 mg/L
Harts
Rocky River — B6000000
Mean TN = 5.76 mg/L
4 6 8
a
LEE
OWatershed Boundary
County Dormdaries
Municipalities
NPDES W W Discharge
Major
Minor
Animal Operation Permits
Cattle
Swine
Monitoring Sites
♦ UCFRBA
♦ NCAMBNT
♦ RAMS 2009 - 2010
® Fish Community
Benthos
USGS Gage
Hydrology
�i Supporting
Not Rated
' N� No Data
' ' . Impaired
Figure 2. Map of Rocky River Watershed. Rocky R. mean TN concentrations for 2010 IR data set. Loves Cr. mean TN conce trations for 4/2009-12/2009 only.
Rocky River (CPF) WQC Update 3 �J%#� I" � l���.;A /2010�

D. Ongoing Actions in the Rocky River Watershed
1) DWQ—
Continued administration of the Rocky River Management Team.
• Raleigh Regional Office (RRO) working with Slier City to assure compliance with the 401 Water Quality
Certification requirements for the newly functioning Turner Reservoir.
• The RRO has reviewed the Nutrient Optimization Plan, as required in the NPDES Permit, conducted two (2)
Compliance Evaluation Inspections in 2010, and met with the Town Manager and wastewater staff to
discuss possible changes to process in order to reduce nutrient loads to Loves Creek. Nutrient (nitrogen)
removal is not currently in place or planned for the Siler City wastewater treatment plant. The RRO has
determined through the inspections the plant is being operated properly and compliant with all permit
limits.
• Staff from Raleigh Regional Office conducted surface water monitoring and assessments to better
understand nutrient fates, pathways and loading occurring in the Rocky River. This data was collected
throughout the watershed during the growing season (e.g. low base flow conditions) from July 14, 2010
through October 6, 2010.
• This information will be used by the RRO to investigate the extensiveness of adjacent land use impacts to
waters. [For example: golf course, single family -sand filter discharges, industries land uses, streamside
gravity sewer lines, cattle access to streams, dry litter poultry operations, waste residuals (sludge) land
applications, etc.] The RRO is in process of systematic efforts to identify sources with specific issues within
the upper reaches of the Rocky River watershed and the Loves Creek catchment.
• Work with the Rocky River Management Team to study the required 20 cfs pulsing from the newly
constructed dam. Provide recommendations back to the Division on possible next steps.
• Assessing best options to aid in watershed wide water quality improvements (e.g. 303(d) listing; nutrient
reductions; modeling; nutrient TMDL due to chlorophyll a exceedances behind Woody's Dam (lower Rocky
River) or Buckhorn Dam (upper Cape Fear River); endangered species).
• Participating (active stakeholder) in watershed restoration, conservation and planning groups.
• Continuing to work with stakeholder on the development and implementation of needed watershed studies.
2) Friends of Rocky River and Rocky River Heritage Foundation —
• Environmental education efforts with the local citizens and high school students.
• Initiated a chlorophyll a study on the lower Rocky River in 2009 (behind Woody's Dam). Data collected in
2009 found elevated chlorophyll a levels. Seventy percent of the samples exceeded the 40 µg/L chlorophyll
a standard. The mean chlorophyll a level for the 10 samples collected was 53.6 µg/L.
• Initiated a periphyton visual watershed assessment in 2009.
• Completed a biological survey of fish, mussels, clams and crayfish in 2010 (Alderman Environmental
Services;
http_://h2o.enr.state.nc.us/basinwide/documents/Rocky River Subbasin Aquatic Taxa Surveys Alderman
Ju12010.Pdf).
• In conjunction with the Triangle Land.Conservancy, assess and prioritize lands on the Rocky River for
volunteer conservation efforts.
• Requesting additional guidance in further watershed studies.
3) 319 Grant—NCSU-WECO initiated in 2009
• Tick Creek watershed restoration plan development.
• Implementing agricultural BMPs as part of this grant.
4) Chatham County
• Chatham Conservation Partnership developing a comprehensive conservation plan for the County.
• Developing a strategic plan for Environmental Resources Division of Chatham County, including watershed
assessments.
Rocky River (CPF) WQC Update 4 12/2010

Rocky River ORANGE
- ALAMANCE 0303000305 1 m
, o i
lerty'
_- ------ - - .------------------------------- --
.ocky; 00*
49,.
�G>- Rive INC
CPF12018 ReservoirJa
O Watershed Boundary
Stale y
e�
421 CPF1201A e,
�
,_.' County Boundaries
�G�
G
C1eek 11�
Municipalities
y9 CHATHAM
Conservation Land
RANDOLPH;
U
= Primary Roads
87
• Non -Discharge Facility
Sller BF58
•
NPDES WW Discharge
city B5950000
64
d
ry
Major
B5890000
B5920000
L
a
L Minor
GS• II
Animal Operation Permits
MeadowBB376
Cattle
cr B5980000
� eok
c0�
�,
® Swine
all teems
Rocky 'v r
B6166
Monitoring Sites
B600000
e Fish Community
13133BF136
Benthos
T�ckCreek Litt
ie
* Lake
Harts Cree
&
Bear Creek
fa USGS Gage
BF56
gocky Ri
Ambient Stations
BB372
• UCFRBA
Bear C
BB495
BB422
• DWQ AMS
reek
• RAMS 2009 - 2010
15
Draft 2012 Use Support
Goldston 421
Supporting
90
Nt
Data inconclusive
NCDWQ
_
��r
�i No Data
BasApril2 12 Planning
April
0 2.5 5
10
Miles
1 -`
i
`N_i Impaired
��_
�

Liberty
Staley
RANDOLPH
Lva�
OSLOEmio
Boundary
Rm0lent lllorvto:l�g 6tetlan
aw,,o* mason
C
B9NCo ftySta%w
NP0e60bcNar
ors
A
Major
U. Support Ba jj
so'."
NIm'trad
NNM
Rated
No Dab,
CWNY a. da`Y
monw'my
Figure 15 Cape Fear River Subbasin 03-06-12
ALAMANCE
CHATHAM
Siler
City aB4az
BB174 BA373
BB20
BF56
a BB210
M
BB376
B0.374
CgaK
BB166.
BB221
BB206
ROCK n
eeµ
BA376
BF72
BB360
BB373
ck
♦
c
mf
BF56 p
2�
BB372 °^
or BM22
3 0 3 6 Miles
a
NCpivision of Water Quality
asinwide Planning Program
August 8,2005