Agenda - 03-17-2009 - 7a - Laserfiche WebLink

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11 Orange Water and Sewer Authority Jordan Lake Comments to NC Environmental Management Commission July 10, 2007 Page 3 of 5 more than 1,500 acres of land acquired by OWASA in fee simple ownership or permanent conservation easements, few, if any, additional management options exist for further reducing nutrient inputs to these reservoirs. With no State or Federal regulatory mandate, we have essentially established total maximum daily loads (TMDLs} for both lakes and implemented the most appropriate nutrient management strategies; yet both lakes continue to exhibit periodically high chlorophyll g concentrations and cyanobacteria episodes. Are these water bodies "impaired?" We don't believe they are; but we do believe that North Carolina's nutrient criteria and related water quality standards are in urgent need of substantial revision. DWQ's EPA- approved Nutrient Criteria Implementation Plan deserves the Commission's full support. Need for a Jordan Lake Use Attainability Analysis What if the Nutrient Strategy and proposed Rules are adopted, but they don't work? Proposed Rules .0265 and .0266 require all local governments in the Jordan Lake watershed to develop stormwater management programs that will achieve and sustain reduced nutrient loads from new and existine development. If the feasibility studies required under the Rules determine that nutrient reduction tazgets for new and existing development aze not attainable due to technical, economic, or administrative constraints, then the Jordan Lake TMDL will not be met and the strate¢v will be deemed a failure. Given the likelihood that this will be the outcome of most, if not all, of the local feasibility studies, we urge the Commission and DWQ to proceed immediately with a Jordan Lake Use Attainability Analysis, as authorized by the Clean Water Act for situations where TMDLs cannot be achieved. l:n the meantime, we urge the Commission to adopt a rational, realistic, and phased approach to implementing the nutrient reduction requirements. Point Source Nutrient Reduction OWASA's Mason Farm Wastewater Treatment Plant has been meeting total phosphorus removal requirements for nearly 20 years. In 2002 we decided to construct multi-million dollar deep bed filters that could remove total nitrogen to the current limits of technology as part of our next facility upgrade -even though OWASA was under no requirement to do so. Those improvements have been completed, and our treatment plant can now remove total nitrogen to the proposed target levels - at least until the plant reaches its new capacity of 14.5 million gallons per day. Additional energy and chemicals needed to achieve the proposed 2016 mass load limit for TN will cost more than $500,000 per year at our current wastewater flow rates, and well over $1 million per year in today's dollars when the plant reaches full capacity in the next 15 to 20 years. Without significant advances in TN removal technology, OWASA will not be able to achieve the proposed annual mass load limit when average day wastewater flows exceed 14.5 million gallons per day, and we may need to restrict additional connections to our wastewater system at that time.