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Home My WebLink AboutNC0020354_Review of Robeson Creek Discharge_20130220 N Cjjp Z o3g y q?,013 • Tl1 IR DENR North Carolina Department of Environment and Natural Resources Division of Water Quality Pat McCrory Charles Wakild, P. E. John E. Skvarla, III Governor Director Secretary February 20,2013 Mayor Randolph Voller Town of Pittsboro \ PO Box 759 635 East Street Pittsboro,North Carolina 27312 Subject: Town of Pittsboro/Review of Robeson Creek Discharge NPDES Permit NCO020354 Dear Mayor Voller: It was a pleasure meeting with you and Bryan!Gruesbeck on January 22, 2013 to discuss potential NPDES wastewater discharge alternatives. This,letter addresses the issues discussed in that meeting and in your letter to me dated December 10, 2012.- Your current permit provides'for a discharge(up to 0.75 MGD) to Robeson Creek, with a future expansion (up to 2.47 MGD) to the Haw River, for a total permitted discharge of 3.22 MGD. Due in part to the high capital costs for a discharge to the Haw River, you requested that Division of Water Quality (DWQ) evaluate the possibility of additional flow being sent to Robeson Creek as an interim wastewater solution. Based on further evaluation by DWQ staff, I offer the following thoughts for your consideration. Apandin F, low to Robgson Creck Beyond 0,75 MGD. The limiting factor for additional wastewater flow to Robeson Creek has been the EPA-approved 2004 Total Phosphorus (TP) TMDL, which results in a fixed TP limit of 322 pounds TP/summer season to Robeson Creek. The entire TMDL point source load was allocated to the Pittsboro WWTP. In order to comply with this TP load limit, Pittsboro would need to achieve the following summer average TP effluent concentrations at the specified flows: 0.75 MGD (0.24 mg/I TP), 1.0 MGD(0.18 mg/l TP), 1.5 MGD (0.12 mg/1 TP), 2.0 MGD (0.09 mg/l TP), 2.5 MGD (0.07 mg/I TP), 3.22 MGD (0.05 mg/l TP). Significant progress has been made over the last decade in phosphorus removal mechanisms,to the point where some facilities are meeting limits less than 0.1 mg/I TP. However, these require specialized attention and specialized TP removal processes,and can be costly. In light of the noted advances in TP reduction, DWQ would be willing to reconsider additional flow to Robeson Creek. As a first step, it is recommended that you seek input from your consulting engineers regarding what additional flow you might propose to discharge to Robeson Creek, based on level of TP treatment required and cost to achieve those levels. Then you might want to schedule another meeting with DWQ for further discussion. Additional steps would include a request to the NPDES Permit Unit 1617 Mail Service Center,Raleigh,North Carolina 27699-1617 Location:512 N•Salisbury St Raleigh,North Carolina 27604 Phone:919-807.63001 FAX:919-807-6492 Internet:wwwmwatereualitv.oro An Equal opportunity 4 Affirmative Action Employer None hCarO 1 a ahmali rt, Mayor Voller February 20,2013 ` Page 2 of 2 for speculative limits for the proposed discharge volume to Robeson Creek, to determine whether there will be any changes to other permit limits(e.g.,BOD,ammonia). It might also be advisable to discuss TP treatment design with DWQ's Infrastructure Finance Section/Design Management Unit, as you would ultimately need to secure an Authorization to Construct (ATC) permit and provide engineering designs for treating TP to low levels. Finally, a reminder that both Robeson Creek and Haw River discharge to Jordan Lake, for which the Jordan Lake TMDL sets both Total Nitrogen and Total Phosphorus mass limits based on the total discharge from Pittsboro WWTP. Potential State Environmental Policv.Act SEPAL Actions. The Town of Pittsboro received a SEPA Environmental Impact Statement(EIS), Record of Decision, on March 19, 2010, for the wastewater expansion to Haw River. If the Town proposes to increase the wastewater discharge to Robeson Creek,this additional flow must be subtracted from the volume allotted to the Haw River discharge, so the total permitted flow remains at 3.22 MGD. If the requested flow expansion to Robeson Creek exceeds 0.5 MGD,then the SEPA EIS must be reopened. Robeson reek Instregm Rea§sessm9nt. Robeson Creek was initially impaired for chlorophyll-a,which was addressed by the development of the Robeson Creek TP TMDL. The creek is still listed as impaired on the 2012 303(d) list for aquatic life. Significant work has been undertaken to improve water quality conditions. DWQ will attempt to re- evaluate the status of the benthic impairment with additional field sampling this summer. I hope this information assists you with your future wastewater planning needs. If you have any questions,please contact me or the following DWQ staff for specific technical questions: NPDES Permitting/Speculative Limits:Tom Belnick,919-807-6390 SEPA Actions:Jeff Manning,919-807-6415 ' ATC Permitting/Design Approval: Seth Robertson,919-707-9175 Robeson Creek Impairment Rating:Kathy Stecker,919-807-6422 Sincerely, Charles Wakild,P.E. Cc:Bryan Gruesbeck,Pittsboro Town Manager ECopy:Ted Bush,Matt Matthews,Kathy Stecker,Seth Robertson,Jeff Manning Danny Smith,Eric Fleek,Tom Belnick,Jeff Poupart RD 1 �Llv\`y E` ✓ ��"6 yl l�"v�_ "�i o.T o�(,{(H� 7 1cl. Iy M1t. .� i.. ! I i c. -�� j x"_� _•�" `��qo - 751 i r,r`I Ke 55 6 �'- I ♦ -- � I \. 9a ` 'YC�r ` _ f+, / � ANO ^0 Q ioo ° S /l\Ai \ ��t. 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C '►ew fer/ �jd .'12.16j WAr/�. /�D1o,eJ4� - S79 -0.0? I 3oQ � O.YcA �.: 4iC hwft �� Q 1 • �v i oew k 7Ov. cred 3 �o) M S�,a� ft {vf w k1 Deb 7 2012 North Carolina 303(d) List-Ca'tegory 5 -a Iva e ped-1 4, Category Rating Use Reason for Rating Parameter Year * 16-(37.5)b Haw River(B. Everett Robeson Creek Arm of Jordan Reservoir 47.0 FW Acres WS-IV,B;NSW,CA 5 Jordan Lake below normal pool elevatio 5 Impaired Aquatic Life Standard Violation Turbidity 2006 5 Impaired Aquatic Life Standard Violation High pH 2006 * 16-38-(3)a '"Robeson Creek 1 From a point 0.7 mile downstream of Chatham County SR 2159 to 0.9 FW Miles WS-[V;NSW 5 Pittsboro Lake Impaired Aquatic Life Fair Bioclassification Ecological/biological Integrity Benthos 1998 * 16-38-(3)c Robeson Creek From Pittsboro Lake to LIT across from SR 1951 2.4 FW Miles WS-IV;NSW 5 1 5 Impaired Aquatic Life Fair Bioclassification Ecological/biological Integrity Benthos 1998 * 16-38-4 Turkey Creek From source to Robeson Creek 4.1 FW Miles WS-IV;NSW 5 5 Impaired Aquatic Life Fair Bioclassification Ecological/biological Integrity Benthos 2012 a-12-d g i t u w�1'r cl 00 -Creek ive Af igit G 0; te, 107 4v > 16-(37.3) HAW RIVER From a point 0.5 mile downstream of US Hwy 64 to approximately 1.0 mil 53.2 FW Acres WS-IV;NSW,CA 5 below US Hwy 64 5 Impaired Aquatic Life Standard Violation High pH 2006 5 Impaired Aquatic Life Standard Violation Turbidity '.2006 --w-jw, ckt,ccll A -840igit Subbasin ;�A, .-,Dee0iRjye Riser 03030, %T W r J 0:037 A*1 W p Ao*F -,0 T- L K —7. F, n f�jrl ra t"a V11 Vrdigi-E-Wafier 30300030 T1 4-4 4ep Medtr River > 17-(4)a DEEP RIVER From dam at Oakdale Cotton Mills,Inc.to SR 1113 2.0 FW Miles WS-IV;CA:* 5 5 Impaired Aquatic Life Standard Violation Low Dissolved Oxygen 2010 HEMa0z iv D X a R ii Friday,August 24,2012 Approved by EPA August 10,2012 Page 12 of 170 �• T$ cl s ROD i�s K 3I i f zo,o i�i�ILoi3 NPOt�P-�f r�— Pybls� 6 �►�� 3/Z9fLolo -� Pe(MI.UK4j 20611 exeireS Z4/6 F7ordorvj C �/�n L ' TP Lim iT = '9731 ) Ll,-)earTN bm(+. ` Z7 Sly ti CA Ib r e c�►vt zos6-1) N,,j OA)l lR- �xis�� ,pZ•y7� � 1 e�Id►r lfeo( FI�aJ = 0.75 �ol�soh (fee K TP TM OL TP I�Ood = 3ZZ 1 b/su�►r��► Plashafo WWTP moo 203Sq r" 1100 I b V/--q m ol jea)04- (4p,1 -0,, 31 = Z1Yd) 3-L-LA ,`f = I. S 0q7 Ne( ®o.7s MC 1.Soy 7.rhe 3 Y x o 75 M&O TP=b.Zy .0 wl® TP= O. I b � lQ m" -rp 0. F2-/ (Wdl-f ® 2MH TP : 0.09 Mj/-I 02,SMO TP. a.0 7 M /,/ � 3.22.� 7P= c�.osMal�P , r r OU I ooh- - JOrAY, to - m �;Q f5 3yx 3.2 ,"P • 3131 �b��r = OAA14 0.3$ mj1 qv<fA)Al TSV • b - <<M►-f, Z�,s14 i /� - 7 Z.� mj �I\lw 84 [Y4c� Ad r hri — .Q3 c�� 3'0 �2 = �.� Cfl --- /leek �o �� / s7t�1�= 71, c�7 30 QL = I Sri Ctrs B�Q �oko�a°�� NCDE�IR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman Governor Director Secretary December 20, 2012 -7f '/Z'101 Z Mayor Randolph Voller Town of Pittsboro p� ►� yytedir) v/ZWO PO Box 759 �'� 635 East Street �:) e 'NPittsboro, NC 27312CAH � no 49 A16-ei,o,, 67e ok Dear Mayor Voller, It was a pleasure speaking with you earlier today about Pittsboro's request to modify the duel- discharge requirement in the Town's current NPDES wastewater discharge permit. The Division of Water Quality is certainly open to reviewing alternatives with you and, as we agreed, a meeting in January is probably the best way to begin some initial discussion of the water quality issues and identify a path forward. We will contact Mr. Gruesbeck for some possible meeting dates and plan to meet here at the Archdale Building in Raleigh. We look forward to working with you and the Town along with other interested parties to find the best solution possible. Please call me if you have questions or wish to discuss this further. Sincerely, Chuck Wakild Cc: Bryan Gruesbeck, Pittsboro Town Manager 1617 Mall Service Center,Raleigh,North Carolina 27699-1617 Location:512 N.Sallsbury SL Raleigh,North Carolina 27604 Phone:919.807.63001 FAX:919.807-6492 Internet:www.ncwateMualiN.oM An Equal Opportunity 1 Af(Kma6va Action Employer NonrthCarolina II . 504 Gtr' Z03 sY- l ss w4 4/7.00 Wi exlevritm Ali eW. �'"� ►M Za�� 001 — .7S ��Iao�t �,r,�lf — i►rytpfi,/�A� V l Ath 1 o , A6jz-(24 X*,O(. 002— Z.y7 I�� -p�1i✓��!-� 6,�ruJ,� �- TN/7If If m,'a> tiv &&404 cmc f-ooZ IA LZ 16 —f Oc.,t 3 01 0. -7 S Af je 3ZZ7p �5To 17 o`�71L/� Z��d 3y x 64 _ 1 MW m�w OO �� '► c7' ,p = ►� l.� T� iAk4livit I M /ZO Belnick, Tom From: Stecker, Kathy Sent: Thursday, January 24, 2013 10:11 AM To: Belnick, Tom Subject: RE: follow-up info for Pittsboro Eric has agreed to go back this year for an update. Will keep you posted. From: Stecker, Kathy Sent: Wednesday, January 23, 2013 10:11 AM To: Belnick,Tom Subject: RE: follow-up info for Pittsboro The biologists typically would not go back to impaired sites in urbanized areas, unless we knew of activities that might have improved the conditions. I will ask Eric to try to schedule an update, because there has been some work in that watershed. From: Belnick,Tom Sent: Wednesday, January 23, 2013 9:36 AM To: Stecker, Kathy Subject: RE: follow-up info for Pittsboro Thanks Kathy. Just one question on Item 3-the biologically impaired sections in Robeson Creek for benthics was established in 1998 (based on 303d list). Have we done updated benthic sampling since then? Tom Belnick Supervisor, NPDES Complex Permitting Unit NCDENR/Division of Water Quality 919-807-6390 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties From: Stecker, Kathy Sent: Tuesday, January 22, 2013 4:45 PM To: Belnick, Tom Cc: Matthews, Matt; Manning, Jeff; Poupart, Jeff; Deamer, Nora Subject: follow-up info for Pittsboro 1. The TMDL did not include any point sources besides Pittsboro;therefore,there is no additional WLA available from the TMDL for them to use. 2. As of 2010,the creek's embayment at Jordan was still not meeting the chlorophyll standard (exceeded in 40%of samples). 3. There are biological impairments in Robeson Creek in Pittsboro. The WWTP is not the only potential cause. The 2005 Cape Fear basin plan says, "The benthic communities were stressed by habitat degradation associated with runoff from urban areas..." I think that's all I was supposed to find out. Let me know if there are questions or you need more info. 1 Kathy Stecker NCDWQ 919-807-6422 NOTICE: Emails sent to and from this account are subject to Public Records Law and may be disclosed to third parties. 2 Zo3S y , Z AfcOOo i 2 Za f TOWN 4F RANDOLPH VOLLER BOARD.OF COMMISSIONERS Mayor 101, PAMELA BALDWIN' tiU'Ii11AM G_TERRY �� J.A.FARRELL ROCCOTowm'Manageir MICHAEL ROCCO € �g BETH'TURNER ; PAUL MESSICK,.JR. �.► J ;,� BETT:WILSON-FOLEY Town Attorney / I TELEPHONE RQ SOX 7159, 635 EAST, sT." � (919)542-4621 PRTSBORO,NC 27312 OFFICE OF THESEC-Rt qRy 09 December 18, 2012 Mme/ �c/ �A Od l 1�6DEC 2012 ENVIRON ENT Secretary Dee Freeman AND,NATURAL RESOURCES rr � NC Department of Environment and,Natural Resources 0 " -1_Cuc 512 North Salisbury Street `#- dLay `Yf'A,�{' --' Raleigh, North Carolina, 27699-1601 t Subject: Request to Review'the Robeson Creek.Discharge for the Town of Pittsboro, NC &"4 ; Loa,, Dear Secretary Freeman. It was a pleasure°chatting with you yesterday. Attached you will find.a letter the Town of Pittsboro has sent to DENR regarding the discharge permit to Robeson Creek along with,letters from the Robeson Creek Watershed Council (RCWC) and the Haw River Assembly on the aforesaid topic. For a variety of sensible environmental, ecological, and economic development reasons, I believe.that the State of North-Carolina in conjunction with the various local stakeholders should allow the Town of E Pittsboro to eliminate or modify the dual-discharge requirement and increase the Town of Pittsboro'6 discharge to Robeson Creek from 0.75 mgd to a level that,is sustainable for•the ecological function of Robeson Creek as well the future of Pittsboro and Chatham County. The Town currently holds a permit to install a pipe,along Robeson Creek for many miles to the east and ultimately discharge an additional 2.47 mgd;of effluent into the Haw River. Besides the extra cost of installing the aforesaid pipe, it is apparent that the installation will potentially damage the creek buffers and ultimately the discharge at the Haw River may be less preferable than permitting a greater discharge of effluent at the Town's current location. It seems logical that a better interim solution would be to allow the Town's updated WWTP plant(we urrentlypro uce reuse quality effluent)to discharge a reasonable amount more at its current location, while other potential solutions and"partnerships are evaluated. (I have attached a map from biologist John Alderman that shows the millions of gallons of effluent already permitted in other watersheds in North Carolina that are potentially comparable to ours.) I hope you can grant that request. CHARTERED 1787 �� 1` Mr. Dee Freeman,Secretary, NCDENR Request to Review Robeson Creek Discharge for Pittsboro, NC date Page 2 of 2 Thank you very much for considering our request. Occasionally situations arise where good public policy can align fiscal prudence with the potential for better long term environmental stewardship. This situation appears to meet that criteria, which has prompted my letter to your office. am happy to meet with you in person or chat on the phone regarding our proposal at 949-1274. Si ly, C'� /L R dy Voller, Mayor T wn of Pittsboro, North Carolina CC: Mr. Bryan Gruesbeck,Town Manager Attachments: (a) Letter to Chuck (b) Letter from Haw River Assembly (c) Letter from Robeson Creek Watershed Council (d) Map from John Alderman Randolph "Randy'S.Voller MAYOR TEL 919-949-1274 Celebrating EMAIL mayorvoller@gmail.com 225 years Town Hall 635 East Street PO Box 759 Pittsboro,NC 27312 TEL (919)542-4621 FAX (919)542-7109 WEB http://pittsboronc.gov/ TOWN OF RANDOLPH VOLLER _`^pBOARD OF COMMISSIONERS Mayor , PAMELA BALDWIN BRYAN L.GRUESBECK �O `� JAY FARRELL Town Manager 0 � MICHAEL A. ROCCO Q SETT WILSON FOLEY PAUL S.MESSICK,JR. ` BETH TURNER Town Attorney TELEPHONE P.O. Box 759—635 East Street (919)542-4621 PITTSBORO,N.C.27312 FAX(919)542-7109 December 10, 2012 Mr. Chuck Wakild, Director Division of Water Quality NC Department of Environment and Natural Resources 512 North Salisbury Street Raleigh, North Carolina, 27699-1601 Subject: Request to-Review-R-obes-on-Greek Dischaige foi Town of Pittsboic, Ne Dear Mr.Wakild: The Town of Pittsboro, NC is fortunate to see early signs of growth and development return to the heart of North Carolina's Piedmont region. As expected, we here in Pittsboro are excited about new economic development opportunities which will add to our rich quality of life and our local business community. However,we are mindful of our responsibility to preserve, protect, and restore the important environmental ; resources of the community that contribute to the rich quality of life afforded in Pittsboro. i We are very grateful to the staff of the North Carolina Department of Environment and Natural Resources (NCDENR)for working closely with the Town of Pittsboro to process our Environmental Impact Statement — (EIS)for a wastewater treatment plant expansion project that included a dual discharge to Robeson Creek (0.75 mgd)and the Haw River(2.47 mgd). The Record of Decision (ROD)for the EIS was issued on March 29, 2010, and the Town received approval for the permit renewal and modification on June 2, 2011. Once j again, I want to extend my sincere appreciation to NCDENR staff for taking the time to work with the Town to achieve this significant milestone for the current and future citizens of Pittsboro. Since receiving the approved permit renewal and modification on June 2, 2011, the Town has been working to evaluate options to implement the wastewater treatment upgrade and expansion project with a dual discharge to Robeson Creek and the Haw River. In August 2012, the Town Board of Commissioners received an engineering report indicating that the capital cost for the discharge to the Haw River was approximately$5.1 million. Given the scope, scale, and nature of this project and the associated costs, the Town of Pittsboro respectfully requests an opportunity to meet with you and representatives of your staff to review the dual discharge requirements defined in the approved permit renewal and modification. Specifically, the Town would like to discuss the possibility of working with NCDENR and other stakeholders on a watershed-based study to evaluate the potential to eliminate or modify the dual-discharge requirement and increase the Town of Pittsboro's discharge to Robeson Creek from 0.75 mgd to a level that is sustainable for the ecological function of Robeson Creek. In making this request to collaborate on a watershed-based study, the Town clearly understands that Robeson Creek was listed as an impaired water body on the 2010 North Carolina 303(d) Impaired Waters List,and that impairment is related to habitat degradation contributions from both non-point and point sources. However, we would very much like to work with NCDENR staff and representatives from the Robeson Creek Watershed Council (RCWC), the Haw River Assembly, the NCSU School of Biological and Agricultural Engineering CHARTERED 1787 Mr. Chuck Wakild, Director, NCDENR December 10, 2012 Page 2 of 2 Department, and other stakeholders to identify the optimum combination of point-and non-point source nutrient reduction measures that can be cost-effectively implemented to mitigate the adverse impacts of excessive nutrient loading, restore the designated uses of Robeson Creek, and accommodate an increased discharge to Robeson Creek from the Pittsboro WWTP. For this purpose of the watershed-based study requested in this letter, the Town would preliminarily view cost-effectiveness in terms of offsetting or minimizing the$5.1 million required to construct an effluent pumping station and outfall to the Haw River, and the associated annual operations and maintenance costs. Please know that the Town of Pittsboro is committed to meeting the Town's responsibilities to achieve phosphorus reduction targets established for the Robeson Creek TMDL and the nitrogen and phosphorus reduction targets established for the Jordan Lake TMDL. However, we believe that a unique opportunity exists for the Town to work collaboratively with NCDENR staff and other important stakeholder groups to identify innovative and creative strategies to cost-effectively meet the TMDL requirements through a combination of planned, coordinated, and targeted nutrient reduction measures for both point and non-point sources of nitrogen and phosphorus. Our ultimate objectives—in order of priority—will be to: ✓ Meet or exceed the effluent limitations and allocations required by the June 2, 2011 permit renewal and modification, including the Robeson Creek TMDL for Total Phosphorous and the Jordan Lake TMDL and stewateFFU le ✓ Work with your staff and other important stakeholder groups to restore the designated uses of Robeson Creek via a holistic watershed-based investigation, ✓ Work to address our impaired 303(d) listed water bodies using point and non-point source nutrient management and education strategies, and; ✓ Receive a renewed permit in 2016 that includes an increase of effluent discharges into Robeson Creek from the Pittsboro WWTP to the extent it is feasible and based on maintaining the ecological function of the receiving waters. Attached to this letter request, are letters of interest from key stakeholder groups that would like to participate with NCDENR staff and the Town of Pittsboro to identify opportunities to preserve, protect, and restore the health and condition of Robeson Creek through innovative and alternative approaches. Rest assured,the Town of Pittsboro has no preconceived expectations regarding the findings of such a watershed-based investigation, but given the magnitude of the costs for an effluent pumping station and pipeline, and the importance of Robeson Creek as a community environmental resource, we believe it is in the best interest of our citizens to make this request of NCDENR at this time. Thank you very much for considering our request. I look forward to meeting with you and your staff soon to discuss the feasibility of initiating this proposed watershed-based investigation which will benefit Robeson Creek, Jordan Lake and the citizens of the Town of Pittsboro. S)and ely, Vo el Mayor Town of Pittsboro, North Carolina Cc: Mr. Dee Freeman, DENR Secretary Mr. Bryan Gruesbeck, Town Manager Attachments: (a) Letter from Haw River Assembly (b) Letter from Robeson Creek Watershed Council Robeson Creek WATERSHED COUNCIL December 5, 2012 To: Mayor Randy Voller and the Pittsboro Town Board of Commissioners RE: Letter of support for the Town of Pittsboro's request for a review of the 0.75 mgd discharge into Robeson Creek Honorable Mayor and Commissioners, The Robeson Creek Watershed Council (RCWC)is comprised of stakeholders, including J representatives of federal, state, and local agencies that have worked together since 2001 to find solutions to the water quality issues in the Robeson Creek watershed. The Robeson Creek watershed drains all of the incorporated limits of the Town of Pittsboro as well as the majority of the ETJ. We appreciate the Town's continued support and participation in the RCWC. Robeson Creek was first placed on the North Carolina State Impaired Waters List(303(d)list)in 1998 for chlorophyll a violations and for a biological impairment on the main stem of Robeson Creek. A total maximum daily load(TMDL) for total phosphorus was developed for Robeson Creek in 2003 to address the chlorophyll a violations in the Robeson Creek cove of Jordan Lake. The TMDL calls for a 71 %phosphorus reduction from urban runoff as well as from the Pittsboro WWTP. Robeson Creek continues to be listed on the 303 (d)both upstream and downstream of Pittsboro's WWTP for impaired aquatic life. After much consideration and discussion of the water quality issues faced by Robeson Creek,the RCWC would like to express our support for a review of the dual discharge permit the town received in June 2011 for a 0.75 mgd discharge to Robeson Creek and a 2.47 mgd discharge to Haw River. We understand that the current permitted discharge of 0.75 mgd into Robeson Creek is based on the USGS hydrologically based 7Q10 flow,which is the lowest 7-day average flow in a ten-year period. Robeson Creek like many Carolina slate belt streams tends to have a low flow especially during the summer months,but unlike many of the surrounding creeks,Robeson Creek generally does not go dry. Currently there is no flow data for Robeson Creek upstream of the WWTP for the basis of the 7Q10. We fully support scientific study of Robeson Creek's stream flow in this critically important stream to more accurately determine this creek's flow so that appropriate discharge flows into the creek can be agreed on. The RCWC would be willing to work with Pittsboro and NCDENR on a watershed-based study to evaluate the possibility of increasing the discharge to Robeson Creek. Ultimately our hope is for the continued restoration and protection of the ecological integrity of Robeson Creek. Sincerely, Catherine Deininger and Karen Hall,Ph.D. Co-Coordinators of the Robeson Creek Watershed Council 1 November 28, 2012 To: The Town of Pittsboro, Mayor Randy Voller and the Pittsboro Board of Commissioners Subject: Letter of Support for Town of Pittsboro's Request to Review Robeson Creek i Discharge i Dear Mayor Voller and Town of Pittsboro Board of Commissioners: The Haw River Assembly supports your request to the NC Department of Natural Resources to review the dual discharge requirements defined in the approved permit renewal and, modification. We agree with your proposal to initiate a watershed-based study to evaluate the potential to eliminate or modify the dual-discharge requirement and increase the Town of Pittsboro's discharge to Robeson Creek from 0.75 mgd to a level that is sustainable for the ecological function of Robeson Creek. We are aware that improvements to the Robeson Creek Watershed and the Town's need to meet the Jordan Lake TMDL requirements underpin any changes to the existing WWTP permit for Pittsboro.We believe there is time and new opportunity to review this dual discharge permit that will result in a less expensive but more effective approach to Pittsboro's wastewater effluent. Based on current population projections and the wastewater treatment capacity for Pittsboro it appears that there is ample time to review better options for water quality and ecosystem health with a new look at what is possible. We strongly support the consideration of a modified permit that would significantly reduce the ; risk to water quality,aquatic life and recreational use in the Haw River at the Highway 64 site created by the 2.47 mgd of treated wastewater that was approved in the dual discharge permit renewal and modification on June 2, 2011. This stretch of river has important Significant Natural Areas, and rare and endangered species incidences and habitat. It is at the public access point for the Lower Haw River State Natural Area which is popular for paddling, fishing,tubing and other recreation. It is only a mile upstream of the impounded waters for Jordan Lake,which is the focus of efforts to reduce nutrient pollution. Eliminating this Haw River,discharge from J_the existing_permit,,while providing sustainable water quality and ecosystem health in Robeson ; Creek,would be a win-win for all. The Town of Pittsboro has a tremendous opportunity to explore the use of proven innovative approaches to treat and reuse wastewater that would otherwise be discharged into the Haw River. This reuse quality water could be used throughout their ETJ including proposed new development. Irrigation reuse and more traditional land application would help restore the local hydrologic cycle which has been impacted by development, increased water withdrawals, and direct discharges of treated wastewater effluent into already impaired surface waters. These and other options could be explored in a more cost-effective and holistic manner to mitigate the adverse impacts of excessive nutrient loading,restore the designated uses of Robeson Creek,and accommodate an increased discharge to Robeson Creek from the Pittsboro WWTP. The Haw River Assembly would like to work with the Town of Pittsboro and other stakeholders to identify opportunities to preserve,protect,and restore the health and condition of Robeson Creek Watershed and receiving streams through innovative and more cost-effective approaches. We support your proposal to NC DENR for this watershed-based study and to explore better options for water quality and ecological health. Sincerely Elaine Chiosso ----c Haw Riverkeeper i I (JPEG 1'magge, 1537 x 1177 pixels)-Scaled(67%) https:/imail-attacliment.goo- eusercontent.com/attachment,'u/6/'?ui=2:.. 6.00000 5 00000 .� ORANGE a6RyAN %00010 zO 6000 10;30900 20 40000010 C)OOD5 iRE0E1l r aAYfbSVf� , 'flflOrlD _ '- 1 ► � 40000A �, RnDesoriCr 380100 < 4LOW c i aAiroairi+ aiw+uw � 16,00010 . siieAiwds. — :MEC K!£JS'a PR6, :3,25✓fiAGD Discharge is on000 Associated Subbasins ®�s`DocDD WANLY ° �COUFA14S OL 9:57000 w E 4 an AUOf-0 0 50 Miles Please see the attached map showing.NPDESpoint sources associated with small watersheds in this general area of NC. As you can see,'there-are many of these associated with small streams. Some of these are quite large. Pittsbor.o is requesting to establish a new point source discharge into the Haw River near US 64. Presently, they are discharging to Robeson Creek. This makes no sense. They should keep the point source where it is. John Alderman iA5 WAS _ t 5 1'+2-c1 t"l �,}O i:!N .5 'F M.A 1 L 14t Seti r'" t PDYe- "ji-1 i N 0111- 5.C.55 t ofJ '-C �k 1 i 1'r`j1jUP---ItS f>(-iz-t\"%T, I of 1 12/19/2012 8:49 AM TONVN OF _ RANDOLPH VOLLER1- BOARD OF COMMISSIONERS Mayor rO�lPAMELA BALDWIN WILLIAM G TERRY � '� J.A.FARRELL Town Manager MICHAEL ROCCO O BETH TURNER PAUL MESSICK,JR. 1 BETT WILSON-FOLEY Town Attomey TELEPHONE P.O.BOX 759, 635 EAST ST. (919)542-4621 PITTSBORO,NC 27312 FAX(919)542-7109 December 18, 2012 Secretary Dee Freeman NC Department of Environment and Natural Resources 512 North Salisbury Street Raleigh, North Carolina, 27699-1601 Subject: Request to Review the Robeson,Creek Discharge for the Town of Pittsboro, NC i i Dear Secretary Freeman: It was a pleasure chatting with you yesterday.Attached you will find a letter the Town of Pittsboro has sent to DENR regarding the discharge permit to Robeson Creek along with letters from the Robeson Creek Watershed Council (RCWC)and the Haw River Assembly on the aforesaid topic. For a variety of sensible environmental, ecological, and economic development reasons, I believe that the _ State of North Carolina in conjunction with the various local stakeholders should allow the Town of Pittsboro to eliminate or modify the dual-discharge requirement and increase the Town of Pittsboro's discharge to Robeson Creek from 0.75 mgd to a level that is sustainable for the ecological function of Robeson Creek as well the future of Pittsboro and Chatham County. I The Town currently holds a permit to install a pipe along Robeson Creek for many miles to the east and ultimately discharge an additional 2.47 mgd of effluent into the Haw River. Besides the extra cost of installing the aforesaid pipe, it is apparent that the installation will potentially damage the creek buffers and ultimately the discharge at the Haw River may be less preferable than permitting a greater discharge of effluent at the Town's current location. It seems logical that a better interim solution would be to allow the Town's updated WWTP plant(we currently produce reuse quality effluent)to discharge a reasonable amount more at its current location, while other potential solutions and partnerships are evaluated. (I have attached a map from biologist John Alderman that shows the millions of gallons of effluent already permitted in other watersheds in North Carolina that are potentially comparable to ours.) I hope you can grant that request. CHARTERED 1787 Mr. Dee Freeman,Secretary, NCDENR Request to Review Robeson Creek Discharge for Pittsboro, NC t date Page 2 of 2 Thank you very much for considering our "request. Occasionally situations arise where good public policy can align fiscal prudence with the pofential for better long term environmental'stewardship..This situation appears to meet that criteria, which has prompted'my letter to your office. I am happy to meet with you in-,person or chat on the phone regarding,our proposal at 949-1274. S'I W- ly; VIIa/'j�k__.._ R ,dy Voller, Mayor T wn of Pittsboro, North Carolina CC: Mr. Bryan Gruesbeck,Town Manager Attachine,ntsi E (a). Letter to Chuck (b) Letter from Haw River Assembly (c) Letter from Robeson Creek'Watershed Council (d) Map from John Alderman TOWN OF - RANDOLPH VOLLER N�RBOARD OF COMMISSIONERS Mayor ON ^ PAMELA BALDWIN BRYAN L. GRUESBECK O� `� MICHAEL A.FARRELL Town Manager ROCCO BETT WILSON FOLEY PAUL S. MESSICK,JR. �, O BETH TURNER Town Attorney TELEPHONE P.O.Box 759-635 East Street a (919)542-4621 PITTSBORO,N.C.27312 FAX(919)542-7109 December 10,2012 Mr. Chuck Wakild, Director Division of Water Quality NC Department of Environment and Natural Resources 512 North Salisbury Street Raleigh, North Carolina,"27699-1601 SuWject:- Request-tc R-evievfRoseso , NC Dear Mr.Wakild: The Town of Pittsboro, NC is fortunate to see early signs of growth and development return to the heart of North Carolina's Piedmont region. As expected,we here in Pittsboro are excited about new economic development opportunities which will add to our rich quality of life and our local business community. However,we are mindful of our responsibility to preserve, protect, and restore the important environmental resources of the community that contribute to the rich quality of life afforded in Pittsboro. We are very grateful to the staff of the North Carolina Department of Environment and Natural Resources (NCDENR)for working closely with the Town of Pittsboro to process our Environmental Impact Statement (EIS)for a wastewater treatment plant expansion project that included a dual discharge to Robeson Creek (0.75 mgd)and the Haw River(2.47 mgd). The Record of Decision (ROD)for the EIS was issued on March 29, 2010, and the Town received approval for the permit renewal and modification on June 2, 2011. 'Once again, I want to extend my sincere appreciation to NCDENR staff for taking the time to work-with the Town to achieve this significant milestone for the current and future citizens of Pittsboro. Since receiving the approved permit renewal and modification on June 2, 2011, the Town has been working to evaluate options to implement the wastewater treatment-upgrade and expansion project with a dual discharge to Robeson Creek and the Haw River. In August 2012, the Town Board of Commissioners received an engineering report indicating that the capital cost for the discharge to the Haw River was approximately$5.1 million. Given the scope, scale, and nature of this project and the associated costs, the Town of Pittsboro respectfully requests an opportunity to meet with you and representatives of your staff to review the dual discharge requirements defined in the approved permit renewal and modification. Specifically, the Town would like to discuss the possibility of working with NCDENR and other stakeholders on a watershed-based study to evaluate the potential to eliminate or modify the dual-discharge requirement and increase the Town of Pittsboro's discharge to Robeson Creek from.0.75 mgd to a level that is sustainable for the-ecological function of Robeson Creek. In making this request to collaborate on a watershed-based study, the Town clearly-understands that Robeson Creek was listed as an impaired water body on the 2010 North Carolina 303(d) Impaired Waters List, and that impairment is related to habitat degradation contributions from both non-point and point sources. However, we would very much like to work with NCDENR staff and representatives from the Robeson Creek Watershed Council (RCWC), the Haw River Assembly, the NCSU School of Biological and Agricultural Engineering CHARTERED 1787 Mr. Chuck Wakild, Director, NCDENR December 10,2012 Fa Paget of 2 Department, and other stakeholders to identify the optimum combination of point--and non-point source nutrient reduction measures that can be cost-effectively implemented to mitigate the'adverse impacts of excessive nutrient loading, restore the designated;uses of Robeson Creek, and accommodate an increased discharge to Robeson Creek from the Pittsboro WV11TP. For this purpose of the watershed-based study requested in this letter,the Town would preliminarily,view cost-effectiveness in terms.of offsetting or minimizing the$5.1 million required.to construct an effluent pumping station and outfall to the Haw River, and the associated annual operations and maintenance costs. Please know that the Town of Pittsboro is committed to meeting the Town's responsibilities to achieve phosphorus reduction targets established for the Robeson Creek TMDL and the nitrogen and phosphorus reduction targets established for the Jordan Lake TMDL. However, we believe that a unique opportunity exists for the Town'to work collaboratively with NCDENR staff and other important stakeholder groups to identify innovative and creative strategies to cost=effectively meet the TMDL requirements through a combination of planned, coordinated, and targeted nutrient reduction measures'for both point and non=point sources of nitrogen and phosphorus,. Our ultimate objectives— in order of priority—will be to: ✓ Meet or exceed the effluent limitations and allocations required by the.June 2, 2011 permit renewal and modification, including the Robeson Creek TMDL for Total Phosphorous and the.Jordan..Lake TMDL and wastewa'LeF Fule ---- ✓ Work With your staff and other important stakeholder group's to restore the designated uses of Robeson Creek via a holistic watershed-based investigation, Work to address our impaired 303(d) listed water bodies using point and ron-point source nutrient management and education strategies, and-, ✓ Receive a renewed permit in 2016 that.includes an increase of effluent discharges into Robeson Creek- from the Pittsboro W VTP to the extent it is feasible and based on,maintaining the ecological function of the receiving waters. .Attached to this letter request, are letters of'interest from key stakeholder groups that would like to participate with NCDENR staff and the Town of Pittsboro to identify opportunities to'preserve, protect, and restore the health and condition of Robeson Creek throuch innovative and alternative approaches. Rest assured', the Town of,Pittsboro has no preconceived expectations regarding,the findings of such a watershed-based investigation, but given the magnitude.of the costs for an effluent pumping station and pipeline, and the importance of Robeson Creek as a community environmental resource;we believe it is in the best interest of our citizens to-make this request of NCDENR at this time. Thank you very much for considering our request. I look forward to meeting with you and'your staff'soon to discuss the feasibility of initiating this proposed watershed-based investigation which will benefit Robeson Creek, Jordan Lake and,the citizens of the Town of Pittsboro. CS)inrely,VfVliel, Mayor tvt Town of Pittsboro, North Carolina Cc: Mr. Dee Freeman, DENR Secretary Mr.,Bryan Gruesbeck, Town Manager Attachments: (a) Letter from Haw River Assembly (b) Letter from Robeson Creek Watershed Council Robeson Creek WATERSHED .COUNCIL 3 December 5,2012 To: Mayor Randy Voller and the'Pittsboro Town Board of Commissioners RE: Letter of support for the Town of:Pittsboro's request for a review of the 0.75 mgd discharge into Robeson Creek Honorable Mayor and Commissioners, The Robeson Creek Watershed Council (RCWC)is comprised of stakeholders,including representatives of federal, state, and local,agencies that have worked together since 2001 to•find solutions to the water quality issues in the Robeson Creek watershed. The Robeson Creek watershed drains all.of the incorporated limits of the Town of Pittsbor`o as well as the majority of: the ETJ. We appreciate the T.own's'coritinued"support and,participation in the RCWC. Robeson Creek was first placed on the North Carolina State Impaired Waters List(303(d)list) in 1998 for chlorophyll a violations mid for a biological impairment on the.main stem of Robeson Creek. A total maximum daily load(TMDL)for total phosphorus was developed for Robeson Creels in 2003 to address the chlorophyll a violations in the Robeson Creels cove of Jordan Lake. The TMDL.calls for a 71 %phosphorus reduction from urban runoff as well as from the Pittsboro VA'WTP. Robeson Creels continues to be listed on the 303 (d)both upstream and- downstream,of Pittsboro's WWTP for impaired aquatic life. After.much consideration and discussion of the water quality issues faced by Robeson Creels, the RCWC would like to express our support for a review of the dual discharge permit the town received in June 2011 for a 0.75 mgd discharge to Robeson Creels and a 2.47 mgd discharge to Haw.River. We understand that the current permitted discharge of 0.75 mgd into Robeson Creek is based on the USGS hydrologically based 7Q 10 flow,which is the lowest 7-day average flow in a ten-year period. Robeson Creels like many Carolina slate belt streams tends to have a'low flow especially during the summer months,but unlike many of the surrounding creeks,Robeson Creels generally does not go dry. Currently there is no flow data.for Robeson Creek upstream of the WWTP for the basis of the 7Q10. We fully support scientific study of Robeson Creek's stream flow in this critically important stream to more accurately determine this creek's flow so that appropriate discharge flows into the creek can be agreed on. The RCWC would be willing to work with Pittsboro and NCDENR on a watershed-based study to evaluate the possibility of increasing the discharge to Robeson Creek. Ultimately our hope is for the continued restoration and protection of the ecological integrity of Robeson Creek. Sincerely, Catherine Deininger and Karen Hall,Ph.D. Co-Coordinators of the Robeson Creek Watershed Council i 4 November 28,2012 To: The Town of Pittsboro, Mayor Randy Voller and the Pittsboro Board of Commissioners Subject: Letter of Support for Town of Pittsboro's Request to Review Robeson Creek Discharge _ Dear Mayor Voller and Town of Pittsboro Board of Commissioners: The Haw River Assembly supports your request to the NC Department of Natural Resources to review the dual discharge requirements defined in the approved permit renewal and modification. We agree with your proposal to initiate a watershed-based study to evaluate the potential to eliminate or modify the dual-discharge requirement and increase the Town of Pittsboro's discharge to Robeson Creels from 0.75 mgd to a level that is sustainable for the ecological function of Robeson Creek. We are aware that improvements to the Robeson Creek Watershed and the Town's need to meet the Jordan Lake TMDL requirements underpin any changes to the existing W WTP permit for Pittsboro. We believe there is time and new opportunity to review this dual discharge permit that will result in a less expensive but more effective approach to Pittsboro's wastewater effluent. Based on current population projections and the wastewater treatment capacity for Pittsboro it appears that there is ample time to review better options for water quality and ecosystem health with a new look at what is possible. We strongly support the consideration of a modified permit that would significantly reduce the risk to water quality, aquatic life and recreational use in the Haw River at the Highway 64 site created by the 2.47 mgd of treated wastewater that was approved in the dual discharge permit renewal and modification on June 2,2011. This stretch of river has important Significant Natural Areas, and rare and endangered species incidences and habitat. It is at the public access point for the Lower Haw River State Natural Area which is popular for paddling,fishing,tubing and other recreation. It is only a mile upstream of the impounded waters for Jordan Lake, which is the focus of efforts to reduce nutrient pollution. Eliminating this Haw River discharge from the existing permit, while providing sustainable water quality and ecosystem health in Robeson Creek,would be a win-win for all. j The Town of Pittsboro has a tremendous opportunity to explore the use of proven innovative approaches to treat and reuse wastewater that would otherwise be discharged into the Haw River. j This reuse quality water could be used throughout their ETJ including proposed new development. Irrigation reuse and more traditional land application would help restore the local- hydrologic cycle which has"been impacted by development, increased water withdrawals, and direct discharges of treated wastewater effluent into already impaired surface waters. These and other options could be explored in a more cost-effective and holistic manner to mitigate the adverse impacts of excessive nutrient loading,restore the designated uses of Robeson Creek,and accommodate an increased discharge to Robeson Creek from the Pittsboro WWTP. The Haw River Assembly would like to work with the Town of Pittsboro and other stakeholders to identify opportunities to preserve,protect, and restore the health and condition of Robeson Creek Watershed and receiving streams through innovative and more cost-effective approaches. We support your proposal to NC DENR for this watershed-based study and to explore better options for water quality and ecological health. j Sincerely Elaine Chiosso Haw Riverkeeper (JPEG Ima(ye, 2537 x 11-77 pixels)- Scaled(67%) htips:ilmail-attaclurnent.goo-1eusercontent.comvattachment7u/O/?rai=2:.. i RACK1fi�at9.Vd �^- 6A0A00 5-00000 PFf2SD7a .fiFANG£ .DURHAM, ' 10 ODDLO - sU.000DG X �O.U00D0 2000000 } " Qr� ® 1 C i 1. pC+UODU� DAV.DSOH .. 4,00000 E OOGOD w.vr RnDvsoH fir. .3 bflUGO i .00060 VtWJJlt=i CHATHAM 16 00000 CnEJ•P.FUS -- - 4 >3,25 MGD Discharge . 24 001300 C0,000Associated Subbasins ®35 UDG00 STNOLYIDOL counties{ 14,$7000 w� yc 40 13D000 ��,YY--// € ® U 50 d7iles Please see the attached map showing NPDES point sources associated with small" watersheds in:this general area of NC As you can see, there are many of these associated with small streams. Some of these are quite large. Pittsboro is requesting to establish a new point source discharge into the Haw River near US 64. Presently, they are discharging to Robeson Creek. This makes no sense. They should keep the point source where it is. John Alderivan 5 lnr'A 5 M, <30H N`S. A i L 14.6 Se,N T— tF5leu-6 0v61—I !NJN 5C_55Lopj w/t5 R&L-o Grtr� �rVt�— r ► T -50 CJ t 1 of 1 12/19/2012 8:49 AM Qelnick, Tom From: Wakild, Chuck Sent: Wednesday, December 19, 2012 1:51 PM To: Matthews, Matt Cc: Smith, Danny; Poupart, Jeff; Belnick, Tom; Bush, Ted Subject: FW: Letter from Mayor Voller Request to Review Robeson Creek Discharge for Town of Pittsboro Attachments: 12.19.12 Mayor Voller Request to review Robeson Creek Discharge for Town of Pittsboro.pdf Importance: High Matt- Let's discuss asap. The letter dated December 10 addressed to me arrived on the 17th and I have the hard copy in my office. From: Jones, Lori Sent: Wednesday, December 19, 2012 1:38 PM To: Wakild, Chuck; Bush,Ted Cc: Smith, Robin; Bownes, Janice H Subject: Letter from Mayor Voller Request to Review Robeson Creek Discharge for Town of Pittsboro Importance: High Chuck, please see the attached and brief the secretary on this matter(either by phone or in person whatever you prefer is fine). He is available this afternoon or tomorrow before noon. Thank you. "ENO , LoriJones Iori.jones@nedenr.gov Executive Assistant to Secretary Dee Freeman&Chief Deputy Secretary Mary Penny Thompson North Carolina Department of Environment and Natural Resources Street Address: 217 W Jones Street,501 floor, Room 5314-D, Raleigh, NC 27603-6100 Mailing Address:1601 Mail Service Center, Raleigh, NC 27699-1601 Telephone: 919-707-8625 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. 1 Gtr 103sY- i ss 4 /zO�► w/ exe&i.um� i1�q To /jA/h /u &44" 002- I.Y7 I*►e ow rooz, �'N ma.� 17Q 1 m o. l ® a 7 s #4f Av3� 3Zz I h 7P o.7- I� &. 3Y so ll - N►GB l� n� TOWN OF i- r: � 1�°dt�l t i✓' f,f+ Jx�—fc��, RANDOLPH VOLLER �� 18� -� �t � �` BOARD OF COMMISSIONERS Mayor , PAMELA BALDWIN BRYAN L. GRUESBECK �` `� 'Gt�`b' �` JAY FARRELL O MICHAEL A. ROCCO Town Manager �� _ _ k�,• _ .. t c` "� � BETT WILSON FOLEY • � r �'��` �" � PAUL S. MESSICK,JR. BETH TURNER� .0 Town Attorney a"+�e�:-� ,/t tc��:a''✓'' TELEPHONE P.O. Box 759—635 East Street `•~ ' (919)542-4621 PITTSBORO, N.C. 27312 `� ( FAX(919)542-7109 �_ • do - �: � ,�"' . December 10, 2012 �� <. VO �> A\, rte. Mr. Chuck Wakild, Director Division of Water Quality NC Department of Environment and Natural Resources 512 North Salisbury Street !� 0f 0 1 Raleigh, North Carolina, 27699-1601 Subject: Request to Review Robeson Creek Discharge for Town of Pittsboro, NC Dear Mr. Wakild: The Town of Pittsboro, NC is fortunate to see early signs of growth and development return to the heart of North Carolina's Piedmont region. As expected, we here in Pittsboro are excited about new economic development opportunities which will add to our rich quality of life and our local business community. However, we are mindful of our responsibility to preserve, protect, and restore the important environmental resources of the community that contribute to the rich quality of life afforded in Pittsboro. We are very grateful to the staff of the North Carolina Department of Environment and Natural Resources (NCDENR) for working closely with the Town of Pittsboro to process our Environmental Impact Statement (EIS)for a wastewater treatment plant expansion project that included a dual discharge to Robeson Creek (0.75 mgd) and the Haw River(2.47 mgd). The Record of Decision (ROD) for the EIS was issued on March 29, 2010, and the Town received approval for the permit renewal and modification on June 2, 2011. Once again, I want to extend my sincere appreciation to NCDENR staff for taking the time to work with the Town to achieve this significant milestone for the current and future citizens of Pittsboro. Since receiving the approved permit renewal and modification on June 2, 2011, the Town has been working to evaluate options to implement the wastewater treatment upgrade and expansion project with a dual discharge to Robeson Creek and the Haw River, In August 2012, the Town Board of Commissioners received an engineering report indicating that the capital cost for the discharge to the Haw River was approximately $5.1 million. Given the scope, scale, and nature of this project and the associated costs, the Town of Pittsboro respectfully requests an opportunity to meet with you and representatives of your staff to review the dual discharge requirements defined in the approved permit renewal and modification. Specifically, the Town would like to discuss the possibility of working with NCDENR and other stakeholders on a watershed-based study to evaluate the potential to eliminate or modify the dual-discharge requirement and increase the Town of Pittsboro's discharge to Robeson Creek from 0.75 mgd to a level that is sustainable for the ecological function of Robeson Creek. In making this request to collaborate on a watershed-based study, the Town clearly understands that Robeson Creek was listed as an impaired water body on the 2010 North Carolina 303(d) Impaired Waters List, and that impairment is related to habitat degradation contributions from both non-point and point sources. However, we would very much like to work with NCDENR staff and representatives from the Robeson Creek Watershed Council (RCWC), the Haw River Assembly, the NCSU School of Biological and Agricultural Engineering CHARTERED 1787 r Mr. Chuck Wakild, Director, NCDENR December 10, 2012 Page 2 of 2 Department, and other stakeholders to identify the optimum combination of point-and non-point source nutrient reduction measures that can be cost-effectively implemented to mitigate the adverse impacts of excessive nutrient loading, restore the designated uses of Robeson Creek, and accommodate an increased discharge to Robeson Creek from the Pittsboro WWTP For this purpose of the watershed-based study requested in this letter, the Town would preliminarily view cost-effectiveness in terms of offsetting or minimizing the$5.1 million required to construct an effluent pumping station and outfall to the Haw River, and the associated annual operations and maintenance costs. Please know that the Town of Pittsboro is committed to meeting the Town's responsibilities to achieve phosphorus reduction targets established for the Robeson Creek TMDL and the nitrogen and phosphorus reduction targets established for the Jordan Lake TMDL. However, we believe that a unique opportunity exists for the Town to work collaboratively with NCDENR staff and other important stakeholder groups to identify innovative and creative strategies to cost-effectively meet the TMDL requirements through a combination of planned, coordinated, and targeted nutrient reduction measures for both point and non-point sources of nitrogen and phosphorus. Our ultimate objectives— in order of priority—will be to. ✓ Meet or exceed the effluent limitations and allocations required by the June 2, 2011 permit renewal and modification, including the Robeson Creek TMDL for Total Phosphorous and the Jordan Lake TMDL and wastewater rule ✓ Work with your staff and other important stakeholder groups to restore the designated uses of Robeson Creek via a holistic watershed-based investigation, Work to address our impaired 303(d) listed water bodies using point and non-point source nutrient management and education strategies, and; ✓ Receive a renewed permit in 2016 that includes an increase of effluent discharges into Robeson Creek from the Pittsboro WWTP to the extent it is feasible and based on maintaining the ecological function of the receiving waters. Attached to this letter request, are letters of interest from key stakeholder groups that would like to participate with NCDENR staff and the Town of Pittsboro to identify opportunities to preserve, protect, and restore the health and condition of Robeson Creek through innovative and alternative approaches. Rest assured, the Town of Pittsboro has no preconceived expectations regarding the findings of such a watershed-based investigation, but given the magnitude of the costs for an effluent pumping station and pipeline, and the importance of Robeson Creek as a community environmental resource, we believe it is in the best interest of our citizens to make this request of NCDENR at this time. Thank you very much for considering our request. I look forward to meeting with you and your staff soon to discuss the feasibility of initiating this proposed watershed-based investigation which will benefit Robeson Creek, Jordan Lake and the citizens of the Town of Pittsboro. Sin rely,DO. 1 y and Vo lel, Mayor Town of Pittsboro, North Carolina Cc: Mr. Dee Freeman, DENR Secretary Mr. Bryan Gruesbeck, Town Manager Attachments: (a) Letter from Haw River Assembly (b) Letter from Robeson Creek Watershed Council r Robeson Creek WATERSHED COUNCIL December 5, 2012 To: Mayor Randy Voller and the Pittsboro Town Board of Commissioners RE: Letter of support for the Town of Pittsboro's request for a review of the 0.75 mgd discharge into Robeson Creek Honorable Mayor and Commissioners, The Robeson Creek Watershed Council (RCWC) is comprised of stakeholders, including representatives of federal, state, and local agencies that have worked together since 2001 to find solutions to the water quality issues in the Robeson Creek watershed. The Robeson Creek watershed drains all of the incorporated limits of the Town of Pittsboro as well as the majority of the ETJ. We appreciate the Town's continued support and participation in the RCWC. Robeson Creek was first placed on the North Carolina State Impaired Waters List(303(d) list) in 1998 for chlorophyll a violations and for a biological impairment on the main stem of Robeson Creek. A total maximum daily load (TMDL) for total phosphorus was developed for Robeson Creek in 2003 to address the chlorophyll a violations in the Robeson Creek cove of Jordan Lake. The TMDL calls for a 71 % phosphorus reduction from urban runoff as well as from the Pittsboro WWTP. Robeson Creek continues to be listed on the 303 (d) both upstream and downstream of Pittsboro's WWTP for impaired aquatic life. After much consideration and discussion of the water quality issues faced by Robeson Creek, the RCWC would like to express our supportfor a review of the dual discharge permit the town received in June 2011 for a 0.75 mgd discharge to Robeson Creek and a 2.47 mgd discharge to Haw River. We understand that the current permitted discharge of 0.75 mgd into Robeson Creek is based on the USGS hydrologically based 7Q 10 flow, which is the lowest 7-day average flow in a ten-year period. Robeson Creek like many Carolina slate belt streams tends to have a low flow especially during the summer months, but unlike many of the surrounding creeks, Robeson Creek generally does not go dry. Currently there is no flow data for Robeson Creek upstream of the WWTP for the basis of the 7Q 10. We fully support scientific study of Robeson Creek's stream flow in this critically important stream to more accurately determine this creek's flow so that appropriate discharge flows into the creek can be agreed on. r The RCWC would be willing to work with Pittsboro and NCDENR on a watershed-based study to evaluate the possibility of increasing the discharge to Robeson Creek. Ultimately our hope is for the continued restoration and protection of the ecological integrity of Robeson Creek. Sincerely, Catherine Deininger and Karen Hall, Ph.D. Co-Coordinators of the Robeson Creek Watershed Council